&EPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-80-029a
August 1980
Air
Sodium Carbonate
Industry -
Background
Information for
Proposed Standards
Draft
EIS
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EPA-450/3-80-029a
Sodium Carbonate Industry
Background Information
for Proposed Standards
by
Emission Standards and Engineering Division
U.S, ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noifio, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina '2 //11
August 1980
-------
This report hau been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standard*, EPA, and approved for publication. Mention of
trade namea or commercial products is not intended to constitute
endorsement or recommendation for use. Copies of this report
are available through the Library Services Office (MD-35),
U.S. Environmental Protection Agency, Research Triangle Park,
N.C. 27711, or from National Technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/3-80-029a
ii
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Background Information
and Draft
Environmental Impact Statement
for Sodium Carbonate Industry
Type of Action: Administrative
Prepared by:
QM
Don R. Goodwin 1 (Date)
Director, Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, N. C. 27711
Approved by:
David G. Hawkins
Assistant Administrator for A1r, Noise, and Radiation
Environmental Protection Agency
Washington, D. C. 20460
Draft Statement Submitted to EPA's
Office of Federal Activities for Review on
(Date)
This document may be reviewed at:
Central Docket Section
Room 2902, Waterside Mall
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460
Additional copies may be obtained at:
Environmental Protection Agency Library (MD-35)
Research Triangle Park, N. C. 27711
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161
111
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METRIC CONVERSION TABLE
In keeping with U.S. Environmental Protection Agency policy, metric
units are used in this report. These units may be converted to common
English units by using the following conversion factors:
Equivalent
Metric Unit Metric Name English Unit
LENGTH
m meter 39.3700 in.
m meter 3.2810 ft.
VOLUME
1 liters 0.2642 U.S. gal.
m3 cubic meters 264.2 U.S. gal.
WEIGHT
Kg kilogram (103 grams) 2.2046 Ib.
Mg megagram (106 grams) 1.1023 tons
Gg gigagram (109 grams) 1,102.3 tons
ENERGY
GJ gigajoule 9.48 X 105 Btu
GJ gigajoule 277.76 KWh
J/g joule per gram 0.430 Btu/lb.
VOLUMETRIC FLOW
NmVsec normal cubic meters per second 2242 SCFM (ft3/min)
Temperature in degrees Celcius (°C) can be converted to temperature
in degrees Fahrenheit t°F) by the following formula;
(°F) = 1.8 (°C) + 32
iv
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TABLE OF CONTENTS
Chapter Page
1 SUMMARY 1-1
1.1 Proposed Standards 1-1
1.2 Environmental Impact 1-3
1.3 Economic Impact 1-3
2 INTRODUCTION 2-1
2 • 1 Background and Authori ty for Standards 2-1
2.2 Selection of Categories of Stationary Sources 2-5
2.3 Procedure for Development of Standards of
Performance 2-7
2.4 Consideration of Costs 2-9
2.5 Consideration of Environmental Impacts 2-10
2.6 Impact on Existing Sources 2-11
2.7 Revision of Standards of Performance 2-12
3 THE SODIUM CARBONATE INDUSTRY 3-1
3.1 General 3-1
3.2 Facilities and Their Em-issions 3-14
3.3 Baseline Emissions 3-51
3.4 References 3-59
4 EMISSION CONTROL TECHNIQUES 4-1
4.1 Description of Control Techniques 4-1
4.2 Application of Control Techniques to
Facilities in the Sodium Carbonate Industry 4-12
4.3 Data Supporting Performance 4-16
4.4 References 4-34
5 MODIFICATION AND RECONSTRUCTION 5-1
5.1 Summary of 40 CFR 60 Provisions for Modifications
and Reconstructions 5-1
5.2 Applicability to Facilities in Sodium Carbonate
Plants 5-3
6 MODEL PLANTS AND REGULATORY ALTERNATIVES 6-1
6.1 Model PI ants 6-1
6.2 Regulatory Alternatives 6-11
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TABLE OF CONTENTS (continued)
Chapter Page
7 ENVIRONMENTAL IMPACT 7-1
7.1 Air Pollution Impact 7-1
7.2 Water Pollution Impact 7-19
7.3 Solid Waste Impact 7-19
7.4 Energy Impact 7-20
7.5 Other Impacts 7-22
7.6 Other Concerns: Commitment of Natural Resources 7-22
7.7 References 7-25
8 ECONOMIC IMPACTS 8-1
8.1 Industry Characterization 8-1
8.2 Cost Analysis of Regulatory Control Alternatives 8-22
8.3 Other Cost Considerations 8-76
8.4 Economic Impact Assessment 8-77
8.5 Socio-Economic Impact Assessment 8-89
3.6 References 8-91
9 RATIONALE FOR THE PROPOSED STANDARD 9-1
9.1 Selection of Source for Control 9-1
9.2 Selection of Pollutants and Affected Facilities 9-2
9.3 Selection of the Basis of the Proposed Standards 9-5
9.4 Selection of the Format of the Proposed Standards 9-9
9.5 Selection of Emission Limits 9-10
9.6 Modification/Reconstruction Considerations 9-14
9.7 Selection of Monitoring Requirements 9-15
9.8 Selection of Performance Test Methods 9-16
9.9 Impacts of Reporting Requirements 9-17
f:
APPENDIX A A-l
APPENDIX B B-l
APPENDIX C C-l
APPENDIX D D-l
APPENDIX E E-l
APPENDIX F F-l
vi
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LIST OF TABLES
Table
1-1 Summary of the Proposed Standards for the Natural
Sodium Carbonate Industry 1-2
1-2 Matrix of Environmental and Economic Impactsof
Regulatory Alternatives -1-5
3-1 The Domestic Sodium Carbonate Industry 3-2
3-2 Uncontrolled EmissionsParameters for Calciners in the
Monohydrate Process 3-19
3-3 Uncontrolled Particulate Emissions from Calciners in
the Monohydrate Process 3 -20
3-4 Uncontrolled Organic Emissions from Calciners 2-22
3-5 Values for Mass and Energy Balances on Calciners
in the Monohydrate Process 3-26
3-6 Uncontrolled Emission Parameters for Dryers in
the Monohydrate and Direct Carbonation Processes 3-34
3-7 Uncontrolled Particulate Emissions from Dryers in
the Monohydrate and Direct Carbonation Processes 3-35
3-8 Values for Mass and Energy Balances on Dryers in the
Monohydrate and Direct Carbonation Processes 3-37
3-9 Uncontrolled Emission Parameters for Predryers in the
Direct Carbonation Process 3-41
3-10 Uncontrolled Particulate Emissions from Predryers in
the Direct Carbonation Process 3-42
3-11 Values for Mass and Energy Balances on Predryers 3-45
3-12 Uncontrolled Emission Parameters for Bleachers in the
Direct Carbonation Process 3-48
3-13 Uncontrolled Particulate Emissions from Bleachers in
the Direct Carbonation Process 3-5C
3-14 Values for Mass and Energy Balances on Bleachers 3-52
3-15 Maximum Allowable Particulate Concentrations for
California 3_56
3-16 Maximum Allowable Solid Particulate Emission Rates
for California 3-57
3-17 Baseline Emission Levels for Model Sodium Carbonate
PI ants 3-58
4-1 Design Parameters and Performance Data Supplied by
Industry for Electrostatic Precipitators Controlling
Emissions from Calciners and Bleachers 4-14
vii
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Table Page
4-2 Design and Operating Parameters and Performance Data
Supplied by Industry for Scrubbers Used to Control
Particulate Emissions from Dryers and Predryers 4-17
4-3 Cyclone/Electrostatic Precipitator Performance
Demonstrated in EPA Tests of a Coal-fired Calciner 4-19
4-4 Cyclone/Electrostatic Precipitator Performance
Demonstrated in EPA Tests of Gas-fired Bleachers 4-22
4-5 Venturi Scrubber Performance Demonstrated in EPA
Tests for a Rotary Steam Tube Dryer 4-25
4-6 Cyclone/Venturi Scrubber Performance Demonstrated in
EPA Tests of a Fluid Bed Steam Tube Dryer 4-28
4-7 Cyclone/Venturi Scrubber Performance Demonstrated in
EPA Tests of Rotary Steam Heated Predryer 4-30
4-8 Cyclone/Venturi Scrubber Performance Demonstrated
in EPA Tests for a Gas-fired Calciner 4-31
4-9 Emission Levels Reported by Industry for Cyclone/
Electrostatic Precipitators on Coal-fired Calciners 4-33
6-1 Model Sodium Carbonate Plants 6-2
6-2 Process Parameters for Model Sodium Carbonate Plants 6-8
6-3 Emission Parameters for Uncontrolled Model Sodium
Carbonate PI ants 6-9
6-4 Regulatory Alternatives for Model Sodium Carbonate
PI ants 6-13
7-1 Stack Parameters for Model Sodium Carbonate Plants 7-3
7-2 Maximum 24-hour Ambient Air Particulate Concentration
due to Emissions from Affected Sodium Carbonate
Facilities 7-10
7-3 Maximum Annual Ambient Air Particulate Concentrations
due to Emissions from Affected Sodium Carbonate
Facilities 7-13
7-4 Comparison of Maximum Ambient Air Concentrations
(ug/m ) due to Emissions from Model Sodium Carbonate
Plants 7-16
7-5 Projected National Emissions from Sodium Carbonate
Plants for 1985 7-18
7-6 Energy Requirements for Model Facilities and Control
Equipment in the Sodium Carbonate Industry 7-21
7-7 Energy Requirements of Projected Sodium Carbonate
Plants 7-23
vm
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Table Page
8-1 The Domestic Sodium Carbonate Industry 8-2
8-2 Uses of Sodium Carbonate (1978) 8-4
8-3 Domestic Sodium Carbonate Production (1967-1978) 8-6
8-4 Synthetic Sodium Carbonate Plant Shutdowns
(1967-1978) 8-7
8-5 Plant Capacities by Year for the Natural Sodium
Carbonate Industry (1967-1979) 8-8
8-6 Projected U.S. Demand and Production of Sodium
Carbonate for 1985 and 2000 8-12
8-7 U.S. Exports Between 1967 and 1978 8-14
8-8 Sodium Carbonate Prices (1967-1978) 8-16
8-9 Raw Material, Labor, Cooling Water, and Energy Usages
for Production of Sodium Carbonate by the Synthetic
and the Monohydrate Process 8-19
8-10 Model Sodium Carbonate Plants 8-23
8-11 Emission Parameters for Uncontrolled Model Sodium
Carbonate Plants 8-24
8-12 Control Options for Model Sodium Carbonate Plants 8-25
8-13 Specifications for Emission Control Systems 8-29
8-14 Factors Used for Estimating Installation-Costs and
Indirect Costs as a Function of Purchased Equipment
Cost (Q) 8-31
8-15 Air Pollution Control Equipment Costs for Sodium
Carbonate PI ants 8-33
8-16 Component Capital Costs for an Electrostatic
Preci pita tor for Case la, 2a, 3a, 4a 8-34
8-17 Component Capital Costs for an Electrostatic
Precipitator for Case Ib, 2b, 3b, 4b 8-35
8-18 Component Capital Costs for a Venturi Scrubber
for Case la, 2a 8-36
8-19 Component Capital Costs for a Venturi Scrubber
for Case Ib, 2b 8-37
8-20 Component Capital Costs for a Venturi Scrubber
for Case 5a, 6a 8-38
8-21 Component Capital Costs for a Venturi Scrubber
for Case 5b, 6b 8-39
8-22 Component Capital Costs for a Venturi Scrubber
for Case 3a, 4a 8-40
ix
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Table Page
8-23 Component Capital Costs for a Venturi Scrubber
for Case 3b, 4b 8-41
8-24 Component Capital Costs for an Electrostatic
Preci pita tor for Case 5a, 6a 8-42
8-25 Component Capital Costs for an Electrostatic
Preci pita tor for Case 5b, 6b 8-43
8-26 Component Capital Costs for a Venturi Scrubber
for Case 5a; 6a; 8-44
8-27 Component Capital Costs for a Venturi Scrubber
for Case 5b, 6b 8-45
8-28 Total Capital Investment for Control of Particulate
Emissions from Facilities in Sodium Carbonate Plants 8-46
8-29 Total Capital Investment for Control of Particulate
Emissions from Model Sodium Carbonate Plants 8-47
8-30 Bases for Annualized Costs of Air Pollution Control
Systems 8-49
8-31 Items Used in Computing Total Annual i zed Costs 8-49
8-32 Recovery Credits for Particulates Removed in
Pol 1 ution Control Systems 8-50
8-33 Component Annualized Costs for an Electrostatic
Preci pi tator for Case la, 2a, 3a, 4a 8-51
8-34 Component Annualized Costs for an Electrostatic
Precipitator for Case Ib, 2b, 3b, 4b 8-52
8-35 Component Annualized Costs for a Venturi Scrubber
for Case la, 2a 8-53
8-36 Component Annualized Costs for a Venturi Scrubber
for Case Ib, 2b 8-54
8-37 Component Annualized Costs for a Venturi Scrubber
for Case 5a, 6a 8-55
8-38 Component Annualized Costs for a Venturi Scrubber
for Case 5b, 6b 8-56
8-39 Component Annualized Costs for a Venturi Scrubber
for Case 3a, 4a 8-57
8-40 Component Annualized Costs for a Venturi Scrubber
for Case 3b, 4b 8-58
8-41 Component Annualized Costs for an Electrostatic
Precipitator for Case 5a, 6a 8-59
8-42 Component Annualized Costs for an Electrostatic
Precipitator for Case 5b, 6b 8-60
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Table Page
8-43 Component Annual! zed Costs for a Venturi Scrubber
for Case 5a , 6a ............................................. 8-61
8-44 Component Annual i zed Costs for a Venturi Scrubber
for Case 5b, 6b ............................................. 8-62
8-45 Annuali zed Costs for Control of Parti cul ate Emissions
from Facilities in Sodium Carbonate Plants .................. 8-63
8-46 Annuali zed Costs for Control of Parti cul ate Emissions
from Model Sodium Carbonate Plants .......................... 8-6^
8-47 Comparison of Cost Estimates of Electrostatic Precipitators. 8-66
8-48 Comparison of Cost Estimates of Venture Scrubbers ........... 8-67
8-49 Cost Effectiveness of Control of Parti cul ate
Emissions from Sodium Carbonate Plants ...................... 8-68
8-50 Cost Effectiveness of Parti cul ate Removal for
Electrostatic Preci pita tor Compared to Cyclone/
Electrostatic Preci pi tator .................................. 8-71
8-51 Uncontrol 1 ed Faci 1 i ty Costs ................................. 8-72
8-52 Energy Costs ................................................ 8-74
8-53 Change In Return on Assets For a 1,000,000 TRY
Plant Assuming No Cost Pass-Through .............. . .......... 8-86
9-1 Projected Emissions from New Sodium Carbonate
Plants in 1985 Under Present Levels of Control .............. 9-3
9-2 Emission Limits for the Regulatory Alternative
and the Proposed Standard ................................... 9-7
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LIST OF ILLUSTRATIONS
Figure Page
3-1 Process flow diagram of the monohydrate process 3-6
3-2 Process flow diagram of the sesquicarbonate
process 3-9
3-3 Process flow diagram of the direct carbonation
process 3-11
3-4 S ol vay process 3-13
3-5 Particle size analysis coal-firedcalciner 3-23
3-6 Particle size analysis gas-fired calciners 3-24
3-7 Material flow rates and energy usage rates
for a medium size calciner in a plant using
monohydrate process 3-27
3-8 Steam tube rotary dryer 3-29
3-9 Direct fired, cocurrent rotary dryer 3-30
3-10 Fluidized-bed dryer 3-31
3-11 Particle size analysis dryers 3-36
3-12 Material flow rates and energy usage rates for
a dryer in a plant using the monohydrate process 3-39
3-13 Particle size analysis predryers 3-44
3-14 Material flow rates and energy usage rates for
predryers in a plant using the direct carbonation
process 3-46
3-15 Particle size analysis bleachers 3-49
3-16 Material flow rates for a bleacher in a plant using the
direct carbonation process 3-53
4-1 Conventional centrifugal separator (cyclone) 4-2
4-2 View of a venturi scrubber with centrifugal
separator chamber 4-5
4-3 Vendor venturi scrubber comparative fractional
efficiency curves 4-6
4-4 View of a typical electrostatic precipitator 4-8
4-5 Example of a fabric filter 4-11
4-6 Controlled particulate emission rates from coal-fired
calciners with cyclone/electrostatic precipitator 4-20
4-7 Controlled particulate concentrations from coal-fired
calciners with cyclone/electrostatic precipitator 4-21
4-8 Controlled particulate emission rates from gas-fired
bleachers with cyclone/electrostatic precipitator 4-23
4-9 Controlled particulate emission rates from rotary steam
tube dryers, fluid bed steam tube dryers, and rotary
steam heated predryer- with venturi scrubbers 4-26
4-10 Controlled particulate concentration from rotary
steam tube dryer, fluid bed steam tube dryer, and
rotary steam heated predryer with venturi scrubbers 4-27
6-1 Model sodium carbonate plant - Configuration 1
(monohydrate process) 6-4
6-2 Model sodium carbonate plant - Configuration 2
(monohydrate process) 6-5
xii
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Figure Page
6-3 Model sodium carbonate plant - Configuration 3
(direct carbonation process) 6-6
7-1 Stack configurations for model sodium carbonate
plants 7-7
8-1 F.O.B. plant prices for natural and synthetic
sodium carbonate normalized to a 1978 base 8-17
8-2 Linear extrapolations of natural sodium carbonate
prices normalized to the 1978 value of money (F.O.B.
plant) 8-20
8-3 Stabil ity of total production of soda ash 8-80
8-4 Relationship between price and production 8-81
xi ii
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1. SUMMARY
1.1 PROPOSED STANDARDS
New Source Performance Standards for participate emissions from
emission sources in the natural sodium carbonate industry are being
proposed under the authority of Section 111 of the Clean Air Act. These
standards will affect new, modified, or reconstructed calciners, dryers,
predryers, and bleachers used in natural process sodium carbonate plants.
There is no growth expected in the synthetic sodium carbonate industry,
and therefore it will not be covered under the standards.
This Background Information Document provides the rationale and
support for the proposed standards. The proposed standards, as stated in
40 CFR Part 60, Subpart II, are summarized in Table 1-1.
The required control of emissions can be achieved by the installation
of particulate control equipment. Venturi scrubbers, alone or in series
with a cyclone, and a combination of a cyclone with an electrostatic
precipitator were demonstrated to be the best emission control systems.
EPA source tests were conducted at three natural process sodium carbonate
plants to demonstrate the particulate control capabilities of these
control systems. Results of these tests are tabulated in Appendix C.
The analysis of the environmental and economic impacts of the pro-
posed standards were based on the following control systems:
calciner - cyclone/electrostatic precipitator
rotary steam tube dryer - venturi scrubber
fluid bed steam tube dryer - cyclone/venturi scrubber
predryer - venturi scrubber
bleacher - cyclone/electrostatic precipitator.
1-1
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TABLE 1-1. SUMMARY OF THE PROPOSED STANDARDS
FOR THE NATURAL SODIUM CARBONATE INDUSTRY
Emission Source
Proposed Standard
Opacity Standard
Caldners
Dryers and predryers
Bleachers
0.11 kg/Mg dry feed
(0.22 Ib/ton)
0.045 kg/Mg dry product
(0.09 Ib/ton)
0.03 kg/Mg dry feed
(0.06 Ib/ton)
5%
10%
5%
1-2
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1.2 ENVIRONMENTAL IMPACT
The analysis of the environmental impact was based on two
alternative regulatory options. These regulatory options were:
1. Control all facilities to the baseline control level.
2. Control all facilities to a more stringent control level
(Proposed Standard).
Alternative 1 is equivalent to no regulatory action. Under this
alternative emissions would be controlled to levels set by existing SIP
regulations. The proposed standards are based on Alternative 2.
In 1985 the proposed standards will reduce emissions of particulate
matter from new sources in natural process sodium carbonate plants by
55 percent over projected emissions under Alternative 1. This reduction in
particulate emissions can be accomplished without causing any adverse primary
or secondary environmental impacts.
Solid wastes generated by the dry collection systems are actually
valuable material which is recycled to the process. Effluents from the
wet collection systems also contain valuable product, and are recycled to
the process. Thus, no water pollution or solid waste impacts result from
the proposed standard. The water required to operate the wet scrubbers
to meet the proposed standards is no more than that which would be used
to meet existing state regulations.
The projected increase in electrical demand of the proposed standards
over the baseline option is less than 1.4 percent of the total energy
required to operate the natural process sodium carbonate plants (about 107
TO/year).
A more detailed analysis of these environmental and energy impacts
is presented in Chapter 7. A summary of the environmental and economic
impacts associated with the proposed standards and the other options
which were considered is presented in Table 1-2.
1.3 ECONOMIC IMPACT
Economic impacts under Alternative 2 would be minimal. Additional
costs to comply with the Alternative 2 control levels would result in a
maximum price increase for sodium carbonate of one percent. This increase
1-3
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could be passed on to sodium carbonate consumers without seriously affecting
the industry. If the costs were to be absorbed by the producers* the
resulting profit reduction would be unlikely to have a major Impact on
the producer's return on assets.
1-4
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TABLE 1-2. MATRIX OF ENVIRONMENTAL AND ECONOMIC IMPACTS
OF REGULATORY ALTERNATIVES
Administrative
Action
Proposed
Standards
(Alternative II)
Alternative I
(no standard,
baseline)
Air
Impact
+3**
0
Water
Impact
0
0
Solid
Waste
Impact
0
0
Energy
Impact
_]***
0
Noise
Impact
-1*
0
Economic
Impact
_!**
0
KEY
:• Beneficial Impact
- Adverse Impact
0
1
2
3
4
*
**
***
No Impact
Negligible Impact
Small Impact
Moderate Impact
Large Impact
Short-Term Impact
Long-Term Impact
Irreversible Impact
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2. INTRODUCTION
2.1 BACKGROUND AND AUTHORITY FOR STANDARDS
Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail. Various levels of control based on different technolo-
gies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for
a standard. The alternatives are investigated in terms of their impacts
on the economics and well-being of the industry, the impacts on the
national economy, and the impacts on the environment. This document
summarizes the information obtained through these studies so that inter-
ested persons will be able to see the information considered by EPA in
the development of the proposed standard.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended,
hereinafter referred to as the Act. Section 111 directs the Admin-
istrator 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."
The Act requires that standards of performance for stationary
sources reflect ". . . the degree of emission reduction achievable which
(taking into consideration the cost of achieving such emission reduction,
and any nonair quality health and environmental Impact and energy
requirements) the Administrator determines has been adequately demon-
strated for that category of sources." The standards apply only to
stationary sources, the construction or modification of which commences
after regulations are proposed by publication in the Federal Register.
2-1
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The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
1. EPA is required to list the categories of major stationary sources
that have not already been listed and regulated under standards of perform-
ance. Regulations must be promulgated for these new categories on the
following schedule:
a. 25 percent of the listed categories by August 7, 1980.
b. 75 percent of the listed categories by August 7, 1981.
c. 100 percent of the listed categories by August 7, 1982.
A governor of a State may apply to the Administrator to add a category not
on the list or may apply to the Administrator to have a standard of perform-
ance revised.
2. EPA is required to review the standards of performance every 4
years and, if appropriate, revise them.
3. EPA is authorized to promulgate a standard based on design, equip-
ment, work practice, or operational procedures when a standard based on
emission levels is not feasible.
4. The term "standards of performance" is redefined, and a new term
"technological system of continuous emission reduction" is defined. The new
definitions clarify that the control system must be continuous and may
include a low- or non-polluting process or operation.
5. The time between the proposal and promulgation of a standard under
Section 111 of the Act may be extended to 6 months.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of achieving such emission reduction, any
non-air-quality health and environmental impacts, and energy requirements.
Congress had several reasons for including these requirements. First,
standards with a degree of uniformity are needed to avoid situations
where some states may attract industries by relaxing standards relative to
other states. Second, stringent standards enhance the potential for
long-term growth. Third, stringent standards may help achieve long-term
2-2
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cost savings by avoiding the need for more expensive retrofitting when
pollution ceilings may be reduced in the future. Fourth, certain types
of standards for coal-burning sources can adversely affect the coal
market by driving up the price of low-sulfur coal or effectively excluding
certain coals from the reserve base because their untreated pollution
potentials are high. Congress does not intend that new source performance
standards contribute to these problems. Fifth, the standard-setting
process should create incentives for improved technology.
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under Section 116 of the Act to establish
even more stringent emission limits than those established under Section
111 or those necessary to attain or maintain the National Ambient Air
Quality Standards (NAAQS) under Section 110. Thus, new sources may in
some cases be subject to limitations more stringent than standards of
performance under Section 111, and prospective owners and operators of
new sources should be aware of this possibility in planning for such
facilities.
A similar situation may arise when a major emitting facility is to
be constructed in a geographic area that falls under the prevention of
significant deterioration of air quality provisions of Part C of the
Act. These provisions require, among other things, that major emitting
facilities to be constructed in such areas are to be subject to best
available control technology. The term Best Available Control Technology
(BACT), as defined in the Act, means
". . . an emission limitation based on the maximum degree of
reduction of each pollutant subject to regulation under this
Act emitted from, or which results from, any major emitting
facility, which the permitting authority, on a case-by-case
basis, taking into account energy, environmental, and economic
impacts and other costs, determines is achievable for such
facility through application of production processes and
available methods, systems, and techniques, including fuel
cleaning or treatment or innovative fuel combustion techniques
2-3
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for control of each such pollutant. In no event shall applica-
tion of 'best available control technology1 result 1n emissions
of any pollutants which will exceed the emissions allowed by
any applicable standard established pursuant to Sections 111
or 112 of this Act. (Section 169(3))."
Although standards of performance are normally structured in terms
of numerical emission limits where feasible, alternative approaches are
sometimes necessary. In some cases physical measurement of emissions
from a new source may be impractical or exorbitantly expensive. Section
lll(h) provides that the Administrator may promulgate a design or equipment
standard in those cases where It 1s not feasible to prescribe or enforce
a standard of performance. For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high concentrations for short periods
during filling and low concentrations for longer periods during storage,
and the configuration of storage tanks make direct emission measurement
impractical. Therefore, a more practical approach to standards of
performance for storage vessels has been equipment specification.
In addition, section 111(1) authorizes the Administrator to grant
waivers of compliance to permit a source to use Innovative continuous
emission control technology. In order to grant the waiver, the
Administrator must find: (1) a substantial likelihood that the technology
will produce greater emission reductions than the standards require or
an equivalent reduction at lower economic energy or environmental cost;
(2) the proposed system has not been adequately demonstrated; (3) the
technology will not cause or contribute to an unreasonable risk to the
public health, welfare, or safety; (4) the governor of the State where
the source 1s located consents; and (5) the waiver will not prevent the
attainment or maintenance of any ambient st^dard. A waiver may have
conditions attached to assure the source will not prevent attainment of
any NAAQS. Any such condition will have the force of a performance
standard. Finally, waivers have definite end dates and may be terminated
earlier if the conditions are not met or if the system falls to perform
as expected. In such a case, the source may be given up to three years
2-4
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to meet the standards with a mandatory progress schedule.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Adminstrator to list categories
of stationary sources. The Administrator ". . . shall include a category
of sources in such list if in his judgement it causes, or contributes
significantly to, air pollution which may reasonably be anticipated to
endanger public health or welfare." Proposal and promulgation of
standards of performance are to follow.
Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of a system for assigning
priorities to various source categories. The approach specifies areas
of interest by considering the broad strategy of the Agency for imple-
menting the Clean Air Act. Often, these "areas" are actually pollutants
emitted by stationary sources. Source categories that emit these
pollutants are evaluated and ranked by a process involving such factors
as: (1) the level of emission control (if any) already required by
State regulations, (2) estimated levels of control that might be required
from standards of performance for the source category, (3) projections
of growth and replacement of existing facilities for the source category,
and (4) the estimated incremental amount of air pollution that could be
prevented in a preselected future year by standards of performance for
the source category. Sources for which new source performance standards
were promulgated or under development during 1977, or earlier, were
selected on these criteria.
The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all major source categories not yet
listed by EPA. These are: (1) the quantity of air pollutant emissions
that each such category will emit, or will be designed to emit; (2) the
extent to which each such pollutant may reasonably be anticipated to
endanger public health or welfare; and (3) the mobility and competitive
nature of each such category of sources and the consequent need for
nationally applicable new source standards of performance.
2-5
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The Administrator is to promulgate standards for these categories
according to the schedule referred to earlier.
In some cases it may not be feasible immediately to develop a
standard for a source category with a high priority. This might happen
when a program of research is needed to develop control techniques or
because techniques for sampling and measuring emissions may require
refinement. In the developing of standards, differences 1n the time
required to complete the necessary investigation for different source
categories must also be considered. For example, substantially more
time may be necessary if numerous pollutants must be investigated from a
single source category. Further, even late in the development process
the schedule for completion of a standard may change. For example,
inablility to obtain emission data from well-controlled sources in time
to pursue the development process in a systematic fashion may force a
change in scheduling. Nevertheless, priority ranking is, and will
continue to be, used to establish the order in which projects are
initiated and resources assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be
determined. A source category may have several facilities that cause
air pollution, and emissions from some of these facilities may vary from
insignificant to very expensive to control. Economic studies of the
source category and of applicable control technology may show that air
pollution control is better served by applying standards to the more
severe pollution sources. For this reason, and because there is no
adequately demonstrated system for controlling emissions from certain
facilities, standards often do not apply to all facilities at a source.
For the same reasons, the standards may not apply to all air pollutants
emitted. Thus, although a source category may be selected to be covered
by a standard of performance, not all pollutants or facilities within
that source category may be covered by the standards.
2-6
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2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must (1) realistically reflect best demon-
strated control practice; (2) adequately consider the cost, the non-air-
quality health and environmental impacts, and the energy requirements of
such control ; (3) be applicable to existing sources that are modified or
reconstructed as well as new installations; and (4) meet these conditions
for all variations of operating conditions being considered anywhere in
the country.
The objective of a program for developing standards is to identify
the best technological system of continuous emission reduction that has
been adequately demonstrated. The standard-setting process involves
three principal phases of activity: (1) information gathering,
(2) analysis of the information, and (3) development of the standard of
performance.
During the information-gathering phase, industries are queried
through a telephone survey, letters of inquiry, and plant visits by EPA
representatives. Information is also gathered from many other sources,
and a literature search is conducted. From the knowledge acquired about
the industry, EPA selects certain plants at which emission tests are
conducted to provide reliable data that characterize the pollutant
emissions from well-controlled existing facilities.
In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies. Hypothetical
"model plants" are defined to provide a common basis for analysis. The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives." These regulatory
alternatives are essentially different levels of emission control.
EPA conducts studies to determine the impact of each regulatory
alternative on the economics of the industry and on the national economy,
on the environment, and on energy consumption. From several possibly
applicable alternatives, EPA selects the single most plausible regulatory
alternative as the basis for a standard of performance for the source
category under study.
2-7
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In the third phase of a project, the selected regulatory alternative
is translated Into a standard of performance, which, 1n turn, 1s written
1n the form of a Federal regulation. The Federal regulation, when
applied to newly constructed plants, will limit emissions to the levels
indicated in the selected regulatory alternative.
As early as 1s practical in each standard-setting project, EPA
representatives discuss the possibilities of a standard and the form 1t
might take with members of the National A1r Pollution Control Techniques
Advisory Committee. Industry representatives and other Interested
parties also participate 1n these meetings.
The Information acquired in the project 1s summarized 1n the Back-
ground Information Document (BID). The BID, the standard, and a preamble
explaining the standard are widely circulated to the Industry being
considered for control, environmental groups, other government agencies,
and offices within EPA. Through this extensive review process, the
points of view of expert reviewers are taken Into consideration as
changes are made to the documentation.
A "proposal package" 1s assembled and sent through the offices of
EPA Assistant Administrators for concurrence before the proposed standard
1s officially endorsed by the EPA Administrator. After being approved
by the EPA Administrator, the preamble and the proposed regulation are
published in the Federal Register.
As a part of the Federal Register announcement of the proposed
regulation, the public is Invited to participate in the standard-setting
process. EPA invites written comments on the proposal and also holds a
public hearing to discuss the proposed standard with Interested parties.
All public comments are summarized and Incorporated Into a second volume
of the BID. All Information reviewed and generated in studies 1n support
of the standard of performance 1s available to the public in a "docket"
on file in Washington, D. C.
Comments from the public are evaluated, and the standard of performance
may be altered 1n response to the comments.
2-8
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The significant comments and EPA's position on the issues raised
are included in the "preamble" of a "promulgation package," which also
contains the draft of the final regulation. The regulation is then
subjected to another round of review and refinement until it 1s approved
by the EPA Administrator. After the Administrator signs the regulation,
1t 1s published as a "final rule" 1n the Federal Register.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111
of the Act. The assessment is required to contain an analysis of
0) the costs of compliance with the regulation, including the extent to
which the cost of compliance varies depending on the effective date of
the regulation and the development of less expensive or mo re-efficient
methods of compliance, (2) the potential inflationary or recessionary
effects of the regulation, (3) the effects the regulation might have on
small business with respect to competition, (4) the effects of the
regulation on consumer costs, and (5) the effects of the regulation on
energy use. Section 317 also requires that the economic impact assessment
be as extensive as practicable.
The economic Impact of a proposed standard upon an industry is
usually addressed both in absolute terms and 1n terms of the control
costs that would be incurred as a result of compliance with typical,
existing State control regulations. An incremental approach is
necessary because both new and existing plants would be required to
comply with State regulations in the absence of a Federal standard of
performance. This approach requires a detailed analysis of the economic
Impact from the cost differential that would exist between a proposed
standard of performance and the typical State standard.
A1r pollutant emissions may cause water pollution problems, and
captured potential air pollutants may pose a solid waste disposal problem.
The total environmental impact of an emission source must, therefore, be
analyzed and the costs determined whenever possible.
2-9
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A thorough study of the profitability and price-setting mechanisms
of the industry is essential to the analysis so that an accurate estimate
of potential adverse economic impacts can be made for proposed standards.
It is also essential to know the capital requirements for pollution
control systems already placed on plants so that the additional capital
requirements necessitated by these Federal standards can be placed in
proper perspective. Finally, it is necessary to assess the availability
of capital to provide the additional control equipment needed to meet
the standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act (NEPA)
of 1969 requires Federal agencies to prepare detailed environmental
impact statements on proposals for legislation and other major Federal
actions significantly affecting the quality of the human environment.
The objective of NEPA Is to build into the decision-making process of
Federal agencies a careful consideration of all environmental aspects of
proposed actions.
In a number of legal challenges to standards of performance for
various industries, the United States Court of Appeals for the District
of Columbia Circuit has held that environmental Impact statements need
not be prepared by the Agency for proposed actions under Section 111 of
the Clean Air Act. Essentially, the Court of Appeals has determined
that the best system of emission reduction requires the Administrator to
take into account counter-productive environmental effects of a proposed
standard, as well as economic costs to the industry. On this basis,
therefore, the Court established a narrow exemption from NEPA for EPA
determination under Section 111.
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to section 7(c)(l)» "No action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the
quality of the human environment within the meaning of the National
Environmental Policy Act of 1969." 05 U.S.C. 793(c)(l))
2-10
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Nevertheless, the Agency has concluded that the preparation of
environmental impact statements could have beneficial effects on certain
regulatory actions. Consequently, although not legally required to do
so by section 102(2)(C) of NEPA, EPA has adopted a policy requiring that
environmental impact statements be prepared for various regulatory
actions, including standards of performance developed under section 111
of the Act. This voluntary preparation of environmental impact state-
ments, however, in no way legally subjects the Agency to NEPA requirements.
To implement this policy, a separate section in this document is
devoted solely to an analysis of the potential environmental impacts
associated with the proposed standards. Both adverse and beneficial
impacts in such areas as air and water pollution, increased solid waste
disposal, and increased energy consumption are discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced ..."
after the proposed standards are published. An existing source is
redefined as a new source if "modified" or "reconstructed" as defined in
amendments to the general provisions of Sub part A of 40 CFR Part 60,
which were promulgated in the Federal Register on December 16, 1975 (40
FR 58416).
Promulgation of a standard of performance requires States to
establish standards of performance for existing sources in the same
industry under Section 111 (d) of the Act if the standard for new sources
limits emissions of a designated pollutant (i.e., a pollutant for which
air quality criteria have not been issued under Section 108 or which has
not been listed as a hazardous pollutant under Section 112). If a State
does not act, EPA must establish such standards. General provisions
outlining procedures for control of existing sources under Section
111 (d) were promulgated on November 17, 1975, as Subpart B of 40 CFR
Part 60 (40 FR 53340).
2-11
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2.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the Act provides that the Administrator ". . . shall, at
least every four years, review and, if appropriate, revise . . ." the
standards. Revisions are made to assure that the standards continue to
reflect the best systems that become available in the future. Such
revisions will not be retroactive, but will apply to stationary sources
constructed or modified after the proposal of the revised standards.
2-12
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3. THE SODIUM CARBONATE INDUSTRY
General information on the sodium carbonate industry is presented
in Section 3.1. The facilities and their emissions are discussed in
Section 3.2.
3.1 GENERAL
Section 3.1 is divided into two sections. Section 3.1.1 presents
background information on the industry, and Section 3.1.2 presents
descriptions of the processes used to produce sodium carbonate.
3.1.1 Industry Background
Sodium carbonate, or soda ash (Na2C03), is a white, crystalline,
hygroscopic powder. It is produced in different product density grades
ranging from 560 kg/m3(35 lb/ft3) to 1250 kg/m3(78 lb/ft3) depending on
the production process.
The major use for sodium carbonate is in the production of glass.
Approximately 50 percent of the 7.3 million megagrams (8.0 million tons)
of sodium carbonate produced in the U.S. in 1978 was used by the glass
industry. Other major users of sodium carbonate and the approximate
percentages of U.S. production accounted for by each in 1978 were the
chemical industry (25%) and the pulp and paper, cleaning agents, and
water treatment industries (16%). Nine percent of U.S. production in
1978 was exported.
As of March 1979, there were eight sodium carbonate plants in the
United States, with a total capacity of approximately 8.5 million megagrams
per year (Mg/yr) or 9.4 million tons per year (TRY). The ownership,
location, startup date, and capacity for each of these plants is presented
in Table 3-1. The process used at each plant is also given.
3-1
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TABLE 3-1 . THE DOMESTIC SODIUM CARBONATE INDUSTRY
Owner
Kerr-McGee
Allied Chem.
FMC Corp.
Stauffer Chem.
Texasgulf, Inc.
Allied Chem.
Plant Name
Trona
West End
Trona
Westvaco
Big Island
Location
Trona, CA
Trona, CA
Green River, WY
Green River, WY
Green River, WY
Green River, WY
Syracuse, NY
Startup
Date3
1978d
f
1968
1972
1947
1962
1976
1881
c Capacity
10° Mg/yr
1.2
0.14
2.0
1.13
1.13
1.54
0.91
0.8
(TRY)
(1.3)
(0.15)
(2.2)
(1.25)
(1.25)
(1.65)
(1.0)
(0.9)
Process
tvoe
Direct carbonation
Direct carbonation
Monohydrate
Monohydrate
Sesqui carbonate
Monohydrate
Monohydrate
Solvay (synthetic)
Empl oy
ment
")
/
\3600C
(
\
1800e
ro
Startup dates are for the original plant unless otherwise stated. See Table 8-6 for expansion
dates. Reference 2.
Capacity data, with the exception of Kerr-McGee's Trona plant are valid through Marchj 1979. The
value for Kerr-McGee's Trona Plant is a planned capacity for year-end 1979.
cValue includes employment for mine and plant. 1978 value. Reference 3.
Kerr-McGee operated a small plant at this location prior to 1978. However, most of the reported
capacity was added in 1978. Reference 3.
Employment value is for the entire plant, which produces calcium chloride, chlorine, caustic soda,
sodium nitrite, ammonium chloride, and sodium sesquicarbonate in addition to soda ash. 1978
value. Reference 4.
fKerr-McGee purchased this plant from Stauffer Chemical Co. in 1974. Actual plant startup was
not determined.
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As indicated in Table 3-1, four different processes are currently
used in the U.S. to produce sodium carbonate. Three of these processes,
the monohydrate, the sesquicarbonate, and the direct carbonation are
classified as natural processes. The fourth, the Solvay process, is
classified as a synthetic process.
In the monohydrate and the sesquicarbonate processes, sodium carbo-
nate is produced by processing naturally occurring deposits of trona ore
(impure sodium sesquicarbonate, Na2C03« NaHCOg-2H20). This ore is found
in large deposits located near Green River, Wyoming.
The first plant to begin processing the trona deposits in Wyoming
used the sesquicarbonate process. This plant was built in 1948, and it
was subsequently expanded during the 1950's and 1960's. These expansions
were the last additions to domestic capacity for producing sodium carbonate
by the sesquicarbonate process. (The reasons that no increases in the
production capacity to produce sodium carbonate by the sesquicarbonate pro-
cess have since been made are discussed in Section 3.1.2.2.) Subsequent
additions to all sodium carbonate production capacity in Wyoming have
involved the construction or expansion of plants using the monohydrate
process.
In the direct carbonation process sodium carbonate is produced from
naturally occurring brine which contains sodium sesquicarbonate, sodium
carbonate, and other salts. Large reserves of this brine are found in
deposits near Trona, California. As indicated in Table 3-1, a large
direct carbonation sodium carbonate plant was recently constructed near
these deposits.
The Solvay process produces sodium carbonate "synthetically" by the
reaction of sodium chloride and limestone. Between the 1860's and the
1970's almost all sodium carbonate production was by the Solvay process.
Since the mid-1960's production by the Solvay process has declined
substantially while natural production has grown by roughly 500 percent.
As indicated in Table 3-1, only one plant in the U.S. currently produces
sodium carbonate by the Solvay process.
One reason for declining Solvay production has been increasing fuel
costs. The Solvay process is more fuel intensive than any of the natural
processes.
3-3
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Environmental issues have also contributed to the decline in the
production of sodium carbonate by the Solvay process. Substantial
quantities of aqueous waste containing high concentrations of calcium
chloride are produced in the Solvay process. Solvay sodium carbonate
plants have traditionally disposed of these non-toxic wastes by dis-
charging to a nearby waterway. Effluent guidelines developed under the
Federal Water Pollution Control Act Amendment of 1972 for Solvay sodium
carbonate plants were remanded; however, the 1972 Amendments introduced
a National Pollutant Discharge Elimination System which provided for the
establishment of effluent and water quality standards for discharges to
a waterway. These standards had a severe impact on the cost of producing
sodium carbonate by the Solvay Process.
The future of sodium carbonate production in the U.S. by the Solvay
process is limited. Allied Chemical Company (currently operating the
only Solvay sodium carbonate plant in the U.S.) has issued statements to
the effect that the construction of any new Solvay plants in the U.S. is
very unlikely. Allied made these statements on the basis of recent
trends in sodium carbonate production and on the expected future trends
in raw materials and energy prices. Personnel with the U.S. Bureau of
Mines have also expressed the opinion that the construction of any new
Solvay plants in the U.S. is unlikely. (The Bureau of Mines compiles
statistics on sodium carbonate production by the natural processes.)
New sodium carbonate plants in the U.S. will most likely use the
monohydrate process, the direct carbonation process, or an anhydrous
p
process. (The anhydrous process is a new process which is currently in
the developmental stage. It involves the same unit operations as the
monohydrate process but the operating conditions of the crystallizer are
such that anhydrous sodium carbonate rather than sodium carbonate monohy-
drate is produced in the crystallizers.) All additions to capacity
which are currently in the planning stages Involve the monohydrate
process. Stauffer Chemical Company and FMC Corporation have expansions
of approximately 270,000 Mg/yr (300,000 TPY) planned for completion in
early 1981. Tenneco plans to complete construction on a new 0.91 million
Mg/yr (1.0 million TPY) plant in Wyoming by 1983.10
3-4
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Sodium carbonate plants using one of the natural processes typically
consist of combinations of separate processing trains. For example, an
existing plant and a planned new plant each consist of two trains of
454,000 Mg/yr (500,000 TRY) each. These trains have some shared equipment
in areas such as ore crushing and liquor clarification, but major process-
ing equipment (such as calciners and dryers) is separate.
Because of the limited availability of natural gas, future plants
are expected to make greater use of coal than existing plants. All
existing monohydrate sodium carbonate plants except one currently use
gas-fired calciners. The newest monohydrate plant in operation uses
coal-fired calciners, and a new plant planned for construction will also
use coal-fired calciners.
3.1.2 Process Description
As noted in Section 3.1.1, four different processes are used in the
U.S. for the production of sodium carbonate. These processes are
described in Sections 3.1.2.1 through 3.1.2.4. These descriptions are
derived from reference 11.
3.1.2.1 Monohydrate Process. In the monohydrate process, sodium
carbonate is produced by the mining and processing of trona ore. A
block flow diagram for the process is shown in Figure 3-1. As indicated,
the twelve processing steps can be divided into four major processing
groups: mining and ore handling, calcining, purification, and product
drying and handling.
Trona ore is mined by conventional room-and-pillar, longwall, contin-
uous mining, and other techniques. Coal mining equipment which has been modi-
fied to handle the harder trona ore is primarily used. The ore may enter the
processing train directly from the mine, or may be discharged to an ore
stockpile. The ore from the stockpile or mine is crushed (usually by
hammer-mills), and screened. Some producers use a single crushing/screening
step, while others use two stages of crushing. A surge bin holds the ore
between the two stages of crushing. Over-sized ore from the second crusher is
recycled back to the second crusher. The sized ore enters a second surne
bin which provides a continuous feed to the calcining operation.
3-5
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Mining
and
Ore Handling
Calcining
Mine
Ore Stockpile
Screening
and Crushing
Calcining
Dissolution
Clarification
and/or Thickening
Purification
Filtering
1
Crystallization
Cen tri fugation
Product Drying
and
Handling
Drying
Cooling
Shipping
Figure 3-1 . Process flow diagram of the monohydrate process
3-6
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In the calciner, the crushed and sized ore is heated to approximately
200°C (400°F). Carbon dioxide and water vapor are driven off, forming
crude sodium carbonate. The calciners used in the mononydrate process
may be fueled with either oil, gas, or coal since impurities resulting
from the fuel will be removed in subsequent purification steps.
The crude sodium carbonate (which also contains insoluble impur-
ities) is fed into leach tanks, or dissolvers, where the sodium carbon-
ate dissolves. The liquor is sent to a clarifier where suspended solids
are allowed to settle. These solids are further dewatered in a secondary
clarifier. The underflow solids are then sent to a tailings pond for
disposal. Overflow liquor from the clarifiers is pressure filtered and
the solids are discarded. Activated carbon may be used to further
remove impurities from the clear liquor.
Multiple effect evaporators are used to crystallize sodium carbon-
ate monohydrate from the clear liquor. The mechanism of crystallization
involves the increase in the concentration of dissolved sodium carbonate
monohydrate until the liquor becomes super-saturated and crystallization is
initiated. The increase in the concentration of dissolved sodium carbonate
is achieved by heating the effects with steam. Vapor from one effect is
used to heat the next effect. The crystallization is carried out at
approximately 100°C (200°F). The slurry from the crystallizers is dewatered
to approximately 5-10 percent water in a high speed centrifuge. The liquor is
returned to the process and the sodium carbonate monohydrate (NaoCO-'HpO)
crystals are transferred to product dryers.
In the product dryers, both free and chemically bound moisture is
evaporated from the sodium carbonate monohydrate at approximately 120 to
180°C(250 to 350°F). The dried product contains approximately 0.1%
moisture. Dried product is fed onto vibrating screens for sizing.
Oversize material is crushed and resized; fines are recycled to the pro-
cess. At some facilities, air clarifiers or rotary tubes with external
cooling water are used to cool the product. Product bulk density is
3 3
about 960 kg/m (60 Ib/ft ). The product is conveyed to intermediate
storage silos and then to loading facilities. Most of the product is
shipped by rail.
3-7
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The operation of and emissions from calciners and dryers used in
the monohydrate process are discussed in Section 3.2.
3.1.2.2 Sesquicarbonate Process. A block flow diagram of the
sesquicarbonate process is shown in Figure 3-2. The processing steps in
the sesquicarbonate process are very similar to those in the monohydrate
process, but the order in which they occur is different.
Mining and ore handling operations are virtually the same as those
discussed in Section 3.1.2.1 for the monohydrate process. Purification
steps are also similar, but raw trona ore is purified before calcining
rather than after calcining as in the monohydrate process. The crystalli-
zer product is purified sodium sesquicarbonate rather than sodium carbonate
monohydrate. In the one U.S. plant using the sesquicarbonate process,
vacuum crystallizers rather than multiple effect evaporators are used.
Sodium sesquicarbonate crystals from the crystallizers are centrifuged
and then calcined.
In the calciners, the purified sodium sesquicarbonate is heated to
approximately 200°C(400°F). Carbon dioxide and water vapor are driven
off, forming pure sodium carbonate. This product has a bulk density of
about 800 kg/m3 (50 Ib/ft ). Some of the product is double calcined to
heat densify it to a bulk density of about 960 kg/m3 (60 Ib/ft3) or
higher.
Since the calcination step follows purification, direct firing of
the calciners with coal or high sulfur oil would result in product con-
tamination with coal ash and sulfur. This makes the use of these fuels
impractical. Steam tube calciners or gas-fired calciners are thus used
in the sesquicarbonate process to prevent product contamination. This
incapability to use dirty fuels for calcination is one major disadvantage
of the sesquicarbonate process over the monohydrate process.
The sesquicarbonate process is also less fuel efficient than the
monohydrate process. It is difficult to achieve the high temperatures
required for calcination in steam-tube calciners. Also, in the monohy-
drate process a high density product is produced directly while in the
sesquicarbonate process light product must be re-calcined in high tempera-
ture gas-fired calciners to produce the higher density product.
3-8
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Mining
and
Ore Handling
Mine
Ore Stockpile
Screening
and Crushing
Dissolution
Clarifying
and/or Thickening
Purification
Filtration
Crystallization
Centrifugation
Calcining
Product
Handling
Calcining
Cooling
Shipping
Figure 3-2. Process flow diagram of the sesquicarbonate process
3-9
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3.1.2.3 Direct Carbonation Process. In the direct carbonation
process, sodium carbonate is produced from brine containing sodium
sesquicarbonate, sodium carbonate, and other salts. A block flow diagram
of the process is shown in Figure 3-3.
The brine is prepared by pumping recycled liquor from the plant and
makeup water into naturally occurring salt deposits. Salts are dissolved
by the liquor as it flows through the porous mineral bed to pumping
wells. These pumps deliver the brine to a surface storage tank. From
this storage tank, the brine is fed to a precarbonation tower where
countercurrent gas-liquid contact with carbon dioxide occurs. Brine is
fed into the top of the tower and flows over polyethylene saddles. A
weak carbon dioxide stream pumped in from the bottom of the tower partially
carbonates the brine.
Further carbonation of the brine occurs in primary and secondary
carbonation towers. This carbonation converts the sodium carbonate to
sodium bicarbonate. This sodium bicarbonate mixture is corrosive, so
all vessel interiors are lined. The weak carbon dioxide stream from the
outlet of these towers is used in the previously discussed precarbonation
step.
Vacuum crystallizers are used to recover sodium bicarbonate from
the brine. Conditions of crystallization are chosen such that the yield
of sodium bicarbonate crystals is maximized and other compounds are not
precipitated. The crystal slurry is filtered, and the filtrate is
returned to the process.
The sodium bicarbonate filter cake enters steam heated predryers
where some of the moisture is evaporated. The temperature in these pre-
dryers is kept below approximately 50°C (122°F) so that no carbon dioxide
is evolved. The partially dried sodium bicarbonate is then further
heated in a steam heated calciner. Carbon dioxide and all remaining water
vapor are driven off, forming impure sodium carbonate. The carbon
dioxide evolved is recycled to the brine carbonators.
Impure sodium carbonate from the calciner is bleached with sodium
nitrate to burn off discoloring materials. The gas- or oil-fired rotary
bleachers operate at 450°C (850°F). The light sodium carbonate from
3-10
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Brine
Brine Preparation
and
Carbonation
Sodium
Bicarbonate
Recovery
Calcining
and
Drying
Precarbonation
Primary
and Secondary
Carbonation
Crystallization
Filtering
Calcining-Drying
Soda
Ash
Purification
*
Bleaching
Recrystallization
Washing
Centrifugation
Product Drying
and
Handling
Drying
Shipping
Figure 3-3. Process flow diagram of the direct Carbonation process
3-11
-------
the bleacher is recrystallized to sodium carbonate monohydrate. Larger,
denser crystals are produced by this step. The crystal slurry is filtered,
and the filter cake is washed to remove impurities such as sodium sulfate
and sodium chloride. The washed crystals are then centrifuged to about
5% moisture.
The monohydrate crystals are transferred to product dryers where
free and bound moisture is evaporated. This drying step is comparable
to that in the monohydrate process. The bulk density of the product is
also the same as that from the monohydrate process, 960 kg/m (60 Ib/ft ).
3.1.2.4 Solvay Process. In the Solvay process, sodium carbonate
is made by carbonating a sodium chloride brine. Ammonia is used as a
catalyst for the reaction. A block flow diagram of the Solvay process
is shown in Figure 3-4. As may be seen, there are 9 major processing
steps.
Coke and limestone are fired to produce lime and carbon dioxide.
Air is fed into the bottom of the kiln; coke and limestone enter at the
top. Carbon dioxide, generated by the decomposition of limestone and
the combustion of carbon in the coke, is pulled off the top of the kiln.
Lime is discharged from the bottom of the kiln into storage bins. It is
then slaked with excess water to produce a thick milk of lime.
Brine is prepared by dissolving sodium chloride in water. This
brine enters the top of an absorption tower, and ammonia-containing
gases enter the bottom. The brine descends through the absorber coun-
tercurrent to the rising gas.
The ammoniated brine is pumped into the top of a series of carbon-
ation towers. Carbon dioxide from the lime kiln bubbles up through the
solution. Gas from the bicarbonate calciners is also used in the carbo-
nation towers. This process step precipitates sodium bicarbonate from
the solution, liberating large amounts of heat.
The crystal slurry from carbonation is concentrated by filtration
where free and fixed ammonia are recovered for use in the ammonia ab-
sorption. Free ammonium compounds are decomposed by heat, and fixed
ammonia is recovered by the reaction of lime with ammonium chloride. A
calcium chloride waste stream is generated from this reaction.
3-12
-------
LIME PREPARATION
AMMONIA RECOVERY
BRINE PROCESSING
CO
u>
Coke-*
Liaeatone -»
Carbon
Dioxide
Figure 3-4. Solvay Process,
-------
The filter cake of crude sodium bicarbonate is washed to remove im-
purities and then calcined to drive off carbon dioxide and water. The
usual apparatus for this process step is a rotary steam tube dryer;
however, a steam tube fluid bed dryer may also be used. The carbon
dioxide and water vapor liberated in this step are recycled to the
carbonation section of the process.
Sodium carbonate from the calciners is cooled and stored in silos.
From storage, the sodium carbonate is distributed either in bulk or
packaged.
3.2 FACILITIES AND THEIR EMISSIONS
There are a number of emission sources within the natural sodium
carbonate industry. The emission sources considered in this study are
calciners, dryers, bleachers, and predryers. These are all process
emission sources which emit significant quantities of particulate matter.
Many potential emission sources in sodium carbonate plants are not
considered in this study because they will be controlled as a result of
other studies. For example, boilers for steam and electricity generation
are being handled under a special category with boilers for all industries,
Many emission sources, including
crushers,
1 grinding mills,
screening operations,
bucket elevators,
conveyor transfer points,
bagging operations,
storage bins, and
fine product (20 mesh and smaller) loading
are being included in a study of the nonmetallic mineral processing
industry.
Other potential emission sources in sodium carbonate plants include
stockpiling, conveying, and windblown dusts. These are fugitive sources
common to many mineral industries rather than process sources, and a
specialized program would be required to identify and study them. Based
3-14
-------
on data presented by the Wyoming Department of Environmental Quality,13
fugitive emissions account for less than 10 percent of the total uncontrolled
emissions from sodium carbonate plants. For these reasons, process emission
sources are emphasized in this study and general fugitive emissions are not
considered.
Dissolvers (and dissolver-crystallizers) are not considered in this
study because they are not significant emission sources. Uncontrolled
emissions from dissolvers are very small compared to the other emission
sources considered. Moreover, all dissolvers built since about 1973 are
currently controlled in order to comply with state opacity regulations
or to control internal dusting problems. Because dissolver emissions
are so small compared to the other process emission sources considered,
control of dissolver emissions to a more stringent level would have very
little impact on national emissions. ^ .
As discussed in Section 3.1, the Solvay proces^> and the sesquicarbo-
nate projc^ss^are not expected to be used in future plants. Thus,~emTssion
sources specific to these processes will not be discussed in this section.
Future sodium carbonate plants are expected to use the monohydrate
process or the direct £air;bonat^on process. As can be seen in the process
flow diagrams in Section 3.1.2, neither of these processes employ all
four of the emission sources considered in this study. The emission
sources specific to thejnonohydrate process are_ca1ciners and dryers,
and those specific to the direct carbonation process are predryers,
j)leachers, and dryers.
Calciners are used in the direct carbonation process, but (as noted
in Section 3.1.2.3) exit gas from these calciners is scrubbed for particu-
late removal and recycled to the carbonation towers. Exit gas from the
carbonation towers is sent to the boilers. Potential pollutants are
thus removed in the process equipment and in the pollution control
equipment on the boilers before the gases are emitted to the atmosphere.^
Therefore, calciners in the direct carbonation process are not considered
to be emission sources.
Each of the facilities being considered in this study of the sodium
carbonate industry is discussed in this section. The discussion is
divided into four sections, one each for calciners, dryers, predryers,
and bleachers.
3-15
-------
3.2.1 Calciners
3.2.1.1 Description. Calciners employed in the monohydrate
process are continuously fed, direct-fired, cocurrent, rotary units.
They consist of a combustion furnace and an inclined rotating cylinder.
Structurally, the cylinder, or rotary section, is similar to that of the
direct-fired, cocurrent, rotary dryer illustrated in Figure 3-9. The
cylinder is constructed of an outer metal shell and may have an inner refrac-
tory brick lining. All or part of the cylinder may be insulated to reduce
heat losses to the environment.
The solid feed is introduced at the elevated end of the cylinder
and moves toward the discharge as a result of gravity and of the rotary
motion of the cylinder. Lifting flights along the inside of the cylinder
aid the movement of the solids and provide intimate mixing with the hot
combustion gases which enter from the furnace. The combustion gases
flow axially in the same direction that the solids move and transfer
heat to the solids as they move through the calciner.
Calciner feed in the monohydrate process consists of crushed and
screened trona ore. This ore typically consists of 86 to 95 percent
sodium sesquicarbonate, 5 to 12 percent gangue (clays and other insoluble
impurities) and approximately 2 percent water. As the ore is heated to
150-200°C (300-390°F) it decomposes or calcines. Carbon dioxide and
water are driven off, and crude sodium carbonate is formed by the following
reaction:
2(Na2C03-NaHC03.2H20) (s)*3 Na2C03(s) + 5H20(g) + C02(g)
Heat of reaction for this endothermic reaction is 44.224 kcal/g-mole
(79,603 Btu/lb-mole) at 25°C (77°F). At calcination temperatures above
200°C (390°F), organic impurities are burned off; however, at these
temperatures soluble sodium silicates are produced by reactions between
sodium carbonate and the clays. These soluble compounds can interfere
with crystallization in the process crystallizers.
Coal, gas, and oil-fired rotary calciners are used in the mono-
hydrate process. Gas firing is currently the most common, and oil
firing is the least common. There are no calciners designed to burn oil
3-16
-------
only, but gas-fired calciners are designed to burn oil during gas short-
ages. At present, coal-fired calciners are used in only one operating
plant. However, due to expected long term shortages of natural gas, a
trend to coal firing is anticipated.
Combustion furnaces on calciners may be of the type illustrated in
Figure 3-9 for a rotary gas-fired dryer, or they may be separate units
connected to the rotary section only by ductwork. The type of furnace
is dependent on the type of fuel combusted.
Coal-fired calciners require a separate combustion furnace with a
coal feeder and rather complicated control equipment. The combustion
furnace for gas-or oil-fired calciners is fairly simple, and may open
directly into the rotary part of the calciner as illustrated in Figure
3-9. As a result of this arrangement, the solids being calcined are
exposed to the flame front, and heat transfer by radiation may be
significant. High overall effective heat transfer coefficients result.
Also, the temperature of the combustion gases in gas- or oil-fired
calciners is generally higher than in coal-fired calciners.
As a result of the higher effective heat transfer coefficients and
the higher combustion gas temperatures in gas- or oil-fired calciners,
higher heat transfer rates per unit mass of solids are achievable.
Thus, more solids can be processed in the same size calciner and less
combustion gas per unit mass of solids is required.
The reported design capacities of calciners used by manufacturers
employing the monohydrate process range from approximately 40 to 163
Mg/h (44 to 180 TPH) of ore feed. However, in some cases the calciner
is normally operated at a rate which is higher than the design operating
capacity. (For example, one calciner is normally operated at a rate
which is approximately 20 percent higher than the design value.) This
is possible because equipment such as calciners is usually over-designed
to allow for design errors; i.e. its actual maximum operating capacity
is sometimes greater than its design operating capacity. In an industry
such as the sodium carbonate industry, where the market demand is relative-
ly strong, plant operators will often run equipment at its maximum
capacity, providing this will not damage equipment or overload other
equipment in the process.
3-17
-------
Calciners at new plants are expected to have capacities of about
118 Mg/h (130 TPH). A calciner of approximately this size would be
required to process enough ore to produce 454,000 Mg/yr (500,000 TRY) of
sodium carbonate, based on an operating factor of 85% and recovery of
90% of the available sodium carbonate in the ore. Larger calciners are
not expected to be built because of regulations on the size of equipment
which can be shipped by rail. Calciners significantly smaller are
currently in use only in older plants.
3.2.1.2 Emissions. Calciners are the largest source of particu-
late emissions from plants using the monohydrate process. These par-
ti culates consist of sodium carbonate and inerts. The exit gas from
coal fired calciners will contain fly ash as well.
Particulate emissions from calciners are affected by the gas velocity
and the particle size distribution of the ore feed. Gas velocity through
the calciner affects the degree of turbulence and agitation. As the gas
velocity increases, the rate of increase in the total emission rate of
particulates steadily increases. (Not enough information is available
to define the effect on particulate concentration.) Particle size
distribution of the ore affects particulate emissions because small
particles are more easily entrained in a moving stream of gas than are
larger particles.
Particulate emission factors, particulate concentrations, and exit
gas flow factors for gas and coal-fired calciners as measured in various
source tests on calciners operating at various production rates are
presented in Table 3-2. Estimated uncontrolled particulate emission
rates, particulate concentrations, and exit gas flow rates extrapolated
from EPA test data presented in Table 3-2 are presented in Table 3-3 for
small, medium, and large gas and coal-fired calciners. As suggested by
the wide range of exit gas flow rates in industry data presented in
Table 3-2, the actual variation in gas flow rates, particulate concentra-
tions, and particulate emission rates for these size calciners may be
much wider than indicated in Table 3-3.
Based on the reported values of particulate emission rate, product loss
3-18
-------
TABLE 3-2. UNCONTROLLED EMISSION PARAMETERS FOR CALCINERS IN THE MONOHYDRATE PROCESS
Source of Data
EPA Test Plant Ac
EPA Test Plant A A
EPA Test Plant B-1
EPA Test Plant B-1
EPA Test Plant B-1,
EPA Test Plant B-2a
EPA Test Plant B-2
EPA Test Plant B-2
Industry Data-Plant A
Industry Data-Plant A (Avg.)
Ind. Data-Plant B-1
Ind. Data-Plant B-1 (Avg.)
Ind. Data-Plant B-2
Ind. Data-Plant B-2 (Avg.)
Ind. Data-Plant C-l
Ind. Data-Plant C-l (Avg.)
Ind. Data-Plant C-2
Ind. Data-Plant C-2 (Avg.)
Ind. Data-Plant 0
Ind. Data-Plant D (Avg.)
Ind. Data-Total Range
Ind. Data-Total Range
Fuel
Coal
Coal
Gas
Gas
Gas
Gas
Gas
Gas
Coal
Coal
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Gas
Coal
Calciner
Size3
M
M
M
M
M
I
I
L
M
M
M
M
L
L
S
S
M
M
M
M
S-L
M
Parti oil ate
Fitriccinn Factor
kg/Hg ore( (lb/ton)ore
222
213
115
195
178
174
157
117f
T
442
425
230
389
356
348
314
233
T
Parti culate
q/dNnT
117
122
167
249
263
238
216
177,
1
Concentration
(gr/dscf)
51.2
53.1
72.8
109
115
104
94.3
77.5,
^^ T
b
Exit,G££ Flow Factor
dNm //If.
1890
1750
696
774
677
734
727
656
1620-1 GOO
1720
612-665
640
540-590
574
834-996
953
618-634
624
684-1360
946
540-1360
1620-1890
dscf/ton
60,500
56,000
22.300
24,800
21 ,700
23,500
23,300
21,000
52,000-57.500
55,000
19,600-21.300
20.500
17,300-18.900
18,400
28.300-31,900
30,700
19,800-20,300
20,000
21,900-43.500
30,300
17,300-43,500
52,000-60,500
aSmall, 40-50 Mg/hr (44-55 tph); Medium, 80-125 Mg/hr (88-138 tph); Large, 200-220 Hg/hr (221-243 tph).
At outlet of control device. EPA tests showed discrepancies between inlet and outlet measurements, and outlet measurements are believed
to be more accurate. Dry flow rate should not be changed by control device.
"•Reference 16.'
Reference 17.
Reference 18.
Uncontrolled emissions were not measured.
-------
TABLE 3-3. UNCONTROLLED PARTICULATE EMISSIONS FROM CALCINERS IN THE MONOHYDRATE PROCESS
(Extrapolated from EPA Test Data.3)
OJ
ro
o
Size
Small
Hed i urt
Large
Ore Feed Rate
Mg/h
(TPH)
4U
(44)
118
/ 1 -3A\
(130)
200
(220)
Fuel
Coalb
Gasb
Coal
Gas
Coalb
Gas
Participate Concentration
g/dftn3
(gr/dscf)
110
(52)
167-263
(73-115)
110
(52)
167-263
C73-1151
116
(52)
178-238
(78-104)
Particulate Emission Rate
kg/h
(lbs/h)
8.5xl03 - 8.8xl03
1.9x10" - 1.0xlOu
4.5xl03 - 7.8xl03
l.OxlO11 - \.7x]0ft
2.5x10? - 2.6x10*
(5.5x107 - 5.7x10*)
1.4x10? - 2.3<10?
(3.0x10* - 5.1x10*)
4.3x10? - 4.4x10?
(9.4x10? - 9.7x10?)
2.3x10? - 3.5x10?
(5.1x10 - 7.7x10 )
Exit Gas Mow Rate
dNm3/min
(dscf/min)
l,?xlol - 1.3x10^
(4.1x10, - 4.4xlOp)
4.5xlOJ - B.ZxlO^
(1.6x10* - 1.8x10*)
3.4x10? - 3.7xl03
(1.2xlo5 - 1.3x10,)
1.3x10: - l.Sxlof
(4.7xl(T - 5.4x10*)
S.SxlO3 - 6.3X103.
(2.1x10, - 2.2x10,)
2.2x10^ - 2.4xlO:J
(7.7x10 - 8.6x10 )
Particulate Emission
Factor kg/Hg
(Ib/ton)
213-222
(425-442)
115-195
(230-389)
213-222
(425-442)
115-195
(230-339)
213-222
(425-«42)
117-1 74
(233-348)
'References 19 and 20.
Particulate concentration is the same as that which was measured for a medium size calciner during source tests. Reported particulate
emission rate and exit gas flow rate are based on values for a medium size calciner weighted for the different ore feedrate.
-------
as a result of participate loading in the exit gas is about 20 to 25
percent of ore feed. Most of this material, however, is routinely
recovered in cyclones and in subsequent particulate removal equipment
and returned to the process.
Particle size distribution data for emissions from gas-and coal-
fired calciners as measured in EPA source tests are presented in Figures
3-5 and 3-6.
Sulfur oxides are produced from fuel combustion. The quantities
produced depend upon the sulfur content of the fuel. The sulfur content
of natural gas is generally insignificant. The sulfur content of coal
and oil is significant; however, it may vary widely. No major seasonal
variations in sulfur oxide levels are expected; however, minor variations
may result when fuel oil is substituted for gas during winter months
when there are natural gas curtailments.
Sulfur dioxide concentrations in the exit gas from a coal-fired
calciner were measured during EPA source tests in May, 1979. The results
of these measurements indicate an emission factor of 0.0076 kg/Mg (0.0152
Ib/ton) of ore feed. However, calculations based on the sulfur content
21
of coal used at this plant and emission factors in an EPA publication
indicate that the sulfur dioxide emission factor should be approximately
1 kg/Mg (2 Ib/ton) of ore feed. Apparently, sulfur dioxide is removed
from the combustion gases by reacting with sodium carbonate in the
calciner before the gases are exhausted.
In addition to the emissions discussed above, organics are emitted
from calciners. These organics may be responsible for the bluish tint
of the exit gases observed at three pi ants. 22,23,24 ^j^ ^-jue ^aze my a-jso
be due to fine particulates.) Concentrations and emission factors for organics
in the exit gases of calciners are reported in Table 3-4.
The source of the organics has not been identified; however, there
are organics present in the feed in the form of oil shale. At the cal-
cination temperatures, these may vaporize or be partially combusted. In
addition, some organics may result from partial or incomplete combustion
of the fuel.
3-21
-------
TABLE 3-4. UNCONTROLLED ORGANIC EMISSIONS FROM CALCINERS3
Source of Data3
EPA Test Plant Ad
EPA Test Plant A
EPA Test Plant Be
EPA Test Plant B
EPA Test Plant Be
EPA Test Plant B
EPA Test Plant B
Fuel
Coal
Coal
6asf
6asf
Gas
Gas
Gas
Calciner
Sizec
M
M
M
M
L
L
L
Organic Concentrations
ppm
30
22
917
2587
47
178
222
aReported on the basis of total organics as methane.
By volume as methane. Emissions as specific compound would be
(ppm as methane) divided by the number of carbon atoms 1n the
compound.
GMedium, 80-125 Mg/hr (88-138 tph); Large, 200-220 Mg/hr (221-243 tph),
Reference 25
Reference 26
These measurements were taken with the caldner operating at low
capacity, and may not be representative of normal operation.
9These emission factors are approximations only. Organics were
reported as ppm methane; the organic species actually present
were not determined.
3-22
-------
I00 99 99 99 9 991 99 9B
90 80 70 60 »l g^^3gg^§^Ui!ii|!iIliaaBBi
!iOSIIldlliiiliiiiiiiIIiil!IiiIiHllifliMiltii!li!iHEiiirjg@^IH!HtniimiBll
l~,r ;rTii -" i'~~l~TirT':"j;!"4JI.J.T z^-H^-I - *^"-- iTl-
arr-fi nT rrrr-LLUi i::.. .. . • .1. . -!—T=rrr—TM-
_, , *.l j_ J . j, t-t-t-- -*-t -• • | I -1 - -• • > —— i— -1 ^ i - . . - »-.,
rf-t-tr 1 i -3- t-.-*-.- J*-^t 'U.l ,.|.. -!_,_ . , , : iTi
Figure
Particle Size Analysis
Coal Fired Calciner
©Anderson Analysis
ElBacho Analysis(composi
sample of 3 tests)
oni oo-j 01 o.; o.s 1
20 30 40 50 60 TO BO
90 9S 98 99
998 999 99 W
Cumulative Percent by Weight Less than (Dp)
3-23
-------
1 OS 0201 0.09 001
S-
«o
Q_
Figure 3-6
Particle Size Analysis
Gas Fired Calciners
illl A Andersen Analysis - calciner #1
lHiO Andersen Analysis - calciner #2 (Tests 1-3)
pQBacho Analysis-calciner #l(composite sample
of 3 tests)
EVBacho Analysis-calciner #2 (composite sample
of 3 tests)
noi nn-, o i n:
20 X •ID SO 60 70 80
I . liln I i • '
Cumulative Percent by Weight less than (Dp)
98 99
3-24
-------
3.2.1.3 Mass and Energy Balances. Energy usage factors, exit gas
flow factors, exit gas temperature, exit gas moisture content, and the
mass ratio of ore feed to sodium carbonate final product are presented
in Table 3-5. Available information does not indicate any significant
variation in these values for different size calciners. The bases for
the reported values are given in the footnotes to Table 3-5.
As noted in Section 3.2.1.1, a capacity of about 118 Mg/h (130 TPH)
of ore feed is expected to be a typical size for future calciners.
Energy usage rate, material flow rates, and exit flow rate for a calciner
of this size are presented in Figure 3.6.
3.2.2 Dryers
3.2.2.1 Description. Dryers are used in both the monohydrate and
direct carbonation processes to remove free and hydrated water from
sodium carbonate monohydrate crystals. Hydrated water is removed by the
following reaction:
Na2C03-H20(s)—>Na2C03(s) + H20 (g)
The heat of reaction is 13.7 kcal/g mole (24,660 Btu/lb mole) at 25°C
(77°F). Supplying the heat to drive this reaction consumes the major
portion of the heat required for drying. Theoretically, the dry monohy-
drate crystals contain about 15 percent hydrated water by weight.
Estimates of the percentage of free water in the monohydrate crystal
feed to dryers in the monohydrate process range from about 5 percent to
30 31 32
15 percent. ' * The free water content of the monohydrate crystal
feed in the direct carbonation process is approximately 5 percent.
Dryers in both processes achieve essentially complete water removal.
Three types of dryers are used for product drying in the mono-
hydrate and direct carbonation processes: rotary steam tube, rotary gas
fired, and fluid bed steam tube. All three dryer types are used by
producers using the monohydrate process. The one producer using the
direct carbonation process uses rotary steam tube dryers. These are
operated in a similar manner to rotary steam tube dryers used by producers
employing the monohydrate process. A general description of the operation
of each type of dryer follows.
3-25
-------
TABLE 3-5. VALUES FOR MASS AND ENERGY BALANCES ON CALCINERS
IN THE MONOHYDRATE PROCESS
PO
Fuel
Coal
Gas
Energy Usage Factor*
J/Mg of Ore
(Btu/ton of ore)
1.6x10* - 1.7xl09
(1.4xl06 - 1.5xlO«)
d
•vl.lxlO9
(^9. 5x1 0s)
e
Exit Gas Flow Factor
dNmVMg of Ore
(dscf/Ton of Ore)
1.6xl03 - 1.7xlOJ
(5.1x10* - 5.5x10")
6.6xl02 - 7.1xl02
2.2x10" - 2.4x10"
Exit Gas b
Temperature
°C
(°F)
200 - 230
(400 - 450)
188 - 200
(370 - 400)
Exit Gas.
Moisture0
Content
%
^20
30 - 38
1g of Calclner Feed (trona ore)
Mg of Final Product (sodium
carbonate)
1.9
1.9
a. The energy usage factors are those which would be supplied by the gross heating value of the fuel.
b. Based on measurements on medium size calciners. (References 27, 28.)
c. Based on an overall material balance on a monohydrate plant. It 1s assumed that the trona ore
contains 83% sodium sesquicarbonate and that 90X of the available Na2COs in the trona ore 1s
recovered as final product.
d. The lower value of the range 1s based on mass and energy balances (ore moisture content ^2%) while
the upper value 1s based on data reported 1n a 1977 Emission Inventory. (Reference 29)
e. The reported value 1s based on mass and energy balances (ore moisture content
-------
Crushed Ore
118 Mg/h
(130 tph)
Energy (Coal)
1.9X1011 - Z.OxlO11 J/h
(l.SxlO8 - 1.95x10° Btu/h)
A1r
Coal-Fired
Calciner
.^Calcined Ore 91 Mg/h (100 tph) total
Exit Gas (^2Q% moisture,
1.9xl05 - 2.0xl05 dNm3/h
(6.6xl06 -7.2xl06 dscf/h)
25 - 26 Mg/hr parti culates
(28 - 29 tph) particulates
dry gas)
00
ro
Crushed Ore 118 Mg/h
(130 tph)
Energy (Natural Gas)
M.SxlO11 J/h
N.2xl08 Btu/h)
Air
Gas-Fired
Calciner
Calcined Ore 91 Mg/h (100 tph) total
Exit Gas (^30-38% moisture, ^2-70% dry gas)
7.8x10" - g'.OxJQ* dNmVh
(2.8xl06 - 3.2xl06 dscf/h)
14-23 Mg/h particulates
(15-26 tph) particulates
Figure 3-7. Material flow rates and energy usage rates for a medium
size calciner in a plant using the monohydrate process
-------
3.2.2.1.1 Rotary steam tube dryers. Rotary steam tube dryers
consist essentially of a metal cylinder with steam tubes fixed length-
wise inside the cylinder. An Illustration of one is presented In Figure
3-8. The end in which feed is Introduced is normally elevated to facili-
tate the flow of solids toward the discharge end. The cylinder and the
steam tubes rotate about the axis of the cylinder. As the cylinder and
steam tubes rotate, the material to be dried falls over the steam tubes
and is heated. This heat evaporates free liquid and dissociates bound
liquid. Air is admitted at one end and withdrawn at the other end to
remove evaporated liquid.
3.2.2.1.2 Rotary gas-fired dryers. An illustration of a rotary
gas fired dryer is presented in Figure 3-9. This type of dryer consists
of a combustion furnace and an inclined rotating cylinder. The cylinder
is constructed of an outer shell and may have an inner refractory lining.
Lengthwise, the shell is either partially or entirely lined. All or
part of the cylinder may be insulated to reduce heat losses to the
environment.
The wet solids are Introduced at the elevated end of the dryer and
move toward the discharge end as a result of gravity and the rotary
motion of the cylinder. Hot combustion gases enter the rotary section
and flow either cocurrently or countercurrently to the direction of
solids flow (Figure 3-9 illustrates a cocurrent dryer). These gases
heat the solids to evaporate free liquid and to dissociate bound liquid.
Significant amounts of heat may also be transferred to the solids by
flame radiation.
3.2.2.1.3 Fluid bed steam tube dryer. An illustration of a fluid
bed steam tube dryer is presented in Figure 3-10. Air is preheated and
introduced into a plenum beneath the fluidizing chamber. This preheated
air then rises through a distributor plate Into the fluidizing chamber.
The wet solids to be dried are entrained (fluidized) in the air stream
at the level of the steam tubes which are located just above the distri-
butor plate. Heat is transferred by convection from the surface of the
steam tubes to the air and from the air to the solids. Heat transferred
to the solids evaporates free liquid, and dissociates bound liquid.
Evaporated liquid is carried out of the dryer in the air stream.
3-28
-------
SECTION A-A
SECTION THROUGH
STEAM MANIFOLD
ro
EXHAUSTGAS
WET FEED
DRIED MATERIAL
DISCHARGE CONVEYOR
STEAM MANIFOLD
STEAM NECK
70-17171
Figure 3-8, Steam tube rotary dryer
33
-------
Feed chule
Combustion
furnoce
Burner
CO
CO
o
Figure 3-9. Direct fired, cocurrent, rotary dryer.
34
-------
EXHAUSTGAS
COLLECTED DUST
CO
i
CO
AIR ?
DUST COLLECTOR
WET FEED
DRY PRODUCT
FLUIDIZING
BLOWER
ro-ino i
35
Figure 3-10. FTuidized-bed dryer.
aThe "steam tubes" are not necessarily tubular in shape. The actual configuration is not shown
because of a confidentiality agreement with the manufacturer using fluid-bed dryers.
-------
The wet feed is introduced continuously into one side of the
fluidizing chamber. The continuous introduction of new material "pushes"
the fluidized bed toward the opposite side of the fluidizing chamber.
The dried solids are removed on this side, opposite from the point where
feed is introduced. One of several techniques may be used to remove the
dried solids. For nontoxic substances dried in an air stream (such as
sodium carbonate) an overflow weir is normally used. The dried solids
overflow this weir and then fall through a discharge chute.
Some solids are carried out of the dryer in the air stream. How-
ever, most of these are normally recovered before the air is discharged
to the atmosphere.
3.2.2.1.4 Comparison of dryers. For both the monohydrate process
and the direct carbonation process, drying and subsequent cooling are
the last processing steps before shipping. Thus, coal or high sulfur
oil cannot be used for direct firing of dryers since this would result
in product contamination with coal ash and sulfur. However, these
energy sources, which may be more available or cheaper than gas, can be
used to generate steam for indirect heating of dryers.
Only one producer currently uses gas-fired dryers. Because of the
short supply and high cost of natural gas, any new dryers in the industry
will probably be steam tube rather than gas-fired.
Three producers currently use rotary steam tube dryers while one
uses fluid bed steam tube dryers. Both types of dryer have relative
advantages and disadvantages.
Generally, greater maintenance is required for rotary steam tube
dryers than for fluid bed steam tube dryers. It is apparently difficult
to prevent leakage around rotary seals, and good rotary units which use
"3C
high pressure steam are reportedly difficult to obtain. A significant
disadvantage of fluid bed steam tube dryers over rotary steam tube
dryers is that larger amounts of gas must be handled by the processing
equipment and by the emission control equipment.
3.2.2.1.5 Size of dryers. The reported maximum operating capa-
cities of dryers used in sodium carbonate plants range from approximately
23 to 113 Mq/h (25 to 130 TPH) of dry sodium carbonate product. Dryers in
3-32
-------
future plants are expected to have capacities of approximately 63 Mg/h
(70 tph) of dry sodium carbonate product. This is the size dryer which
would be required to produce 454,000 Mg/yr (500,000 TRY) of sodium
carbonate, assuming an annual operating factor of 85 percent.
3.2.2.2. Emissions. Sodium carbonate fines are emitted from each
of the three types of dryers used. Particulate emission factors,
particulate concentrations, and exit gas flow factors from rotary and
fluid-bed dryers and gas flow factors from gas-fired dryers measured
during source tests are presented in Table 3-6. Estimated uncontrolled
particulate emission rates, particulate concentrations, and exit gas
flow rates for small and medium sized rotary dryers and for medium and
large fluid bed dryers extrapolated from EPA test data are presented in
Table 3-7. No data on uncontrolled particulate emission rates for gas-
fired dryers are available.
Particle size distributions for rotary steam tube and fluid bed
steam tube dryers are presented in Figure 3-11.
Particulate emissions from dryers are affected by the gas velocity
and the particle size distribution of the feed. Gas velocity through
the dryer affects the degree of turbulence and agitation. As the gas
velocity increases, the rate of increase in the total emission rate of
particulates steadily increases. (Not enough information is available
to define the effect on particulate concentration.) Therefore, because
of higher gas flow rates (and higher gas velocities), fluid bed steam
tube dryers and rotary gas-fired dryers have higher emission rates than
rotary steam tube dryers. Particle size distribution of the ore affects
particulate emissions because small particles are more easily entrained
in a moving stream of gas than are larger particles.
3.2.2.3 Mass and Energy Balances. Values for mass and energy
balances on dryers in the monohydrate and direct carbonation processes
are presented in Table 3-8. Factors for energy usage and exit gas flow
per unit mass of product are presented along with exit gas temperature
and moisture content and the mass ratio of monohydrate crystal feed to
dry sodium carbonate product. The factor for exit gas flow was calculated
by assuming a free water content of 10 percent in the dryer feed slurry
3-33
-------
TABLE 3-6. UNCONTROLLED EMISSION PARAMETERS FOR DRYERS IN THE MONOHYDRATE
AND DIRECT CARBONATION PROCESSES.
to
CO
ST • rotary steam tube, FB - fluid bed steam tube; GF • Gas-fired rotary.
bS - Small, 20-30 Mg/hr
M • Medium, 5C 70 Mg/hr
L - Large. 90-130 Mg/hr
c Flow rate Is at exit of scrubber.
Reference 37.
'Reference 38.
Reference 39.
Source of Data
EPA Test-Plant Ad
EPA Test-Plant Be
Industry Data-Plant Af
Industry Data-Plant A (Avg.)
Industry Data-Plant B
Industry Data-Plant B (Avg.)
Industry Data-Plant C
Industry Data-Plant C (Avg.)
Industry Data-Plant D
Industry Data-Plant 0
Industry Data-Plant D (Avg.)
Dryer
Type*
ST
ST
ST
FB
FB
FB
ST
ST
FB
FB
ST
ST
GF
GF
GF
Dryerfc
Size"
M
M
M
L
L
L
M
M
M
L
S
S
M
L
Partlculate
kg/Mg dry
Product
28.6
33.9
25.6
116
52.5
51.5
-
-
-
-
-
-
-
-
Emission Factor
Ib/ton dry
Product
57.2
67.7
51.1
231
105
103
-
-
t-
-
-
-
•-
-
Partlculate
g/dHn3
73.9
68.6
77.1
90.8
44.2
41.9
-
-
-
-
-
-
-
-
Concentration
gr/dscf
32.3
30.0
33.6
39.7
19.3
18.3
-
-
-
-
-
-
-
-
Exit Gas Flow Factor0
dNm3/Hg
dry product
387
493
331
1340
412-562
509
1250
855
285-581
416
1350-1790
568-659
1250
dscf/ton
dry product
12,400
15,800
10,600
43,000
13.10Q-18.000
16,300
40,000
27.400
9120-18,600
13,400
43,300-57,400
18,200-21,100
40,100
-------
TABLE 3-7. UNCONTROLLED PARTICIPATE EMISSIONS FROM DRYERS IN THE MONOHYDRATE AND
DIRECT CARBONATION PROCESSES (EXTRAPOLATED FROM EPA TEST DATA)3
Dryer Type
Rotary Steam
Tube '
Rotary Steam
Tube
Fluid Bed
Steam Tube
Fluid Bed
Steam Tube
Size
Small
Medium
Medium
Large
Production
Rate (Dry
Product)
Mg/hr
(tph)
23
(25)
63
(70)
63
(70)
113
(130)
Parti cul ate Emis-
sion Factor
kg/Mg
(Ib/ton)
25.6 - 33.9
(51.1 - 67.7)
25.6 - 33.9
(51.1 - 67.7)
51.5 - 116
(103 - 231)
51.5 - 116
(103 - 231)
Parti cul ateJEnrls-
sion Rate
kg/hr
_05/hrl
581 - 767
(1280 - 1690)
1620 - 2150
(3500- 4740)
3270 - 7350
(7210 - 16,200)
6080 - 13,600
(13,400 - 30,000)
Parti cul ate
Concentration
g/dNnr
(gr/dscf)
69 - 77
(30 - 34)
69 - 77
(30 - 34)
42 - 91
(18 - 40)
42 - 91
(18 - 40)
Exit Gask
Flow Rate6
dtaT/min
(dscf/min)
125 - 186
(4420 - 6580)
351 - 521
(12,400 - 18,400)
M420
K50.200)
•v.2600
(•v.94,500
co
co
ui
Reference 40,41.
kparticulate emission rate and exit gas flow rate were calculated by ratioing values measured in source
tests according to production rate.
-------
100 9099 999 991
99 98 95 90
Figure 3-11
Particle Size Analysis
Dryers
Bacho Analysis of Rotary Steam Tube Dryer H
(composite sample of 3 tests) -^-
Anderson Analysis of Fluid Bed Steam Tube:j§
Dryer "
Bacho Analysis of Fluid Bed Steam Tube
Dryer (composite of 3 tests)
20 X « SO 60 70 80
noi no-i 0102 05
Cumulative Percent by Weight less than (Dp)
3-36
-------
TABLE 3-8. VALUES FOR MASS AND ENERGY BALANCES ON DRYERS IN THE
MONOHYDRATE AND DIRECT CARBONATION PROCESSES
CO
i
CO
Dryer
Type
Rotary
Steam
Tube
Fluid Bed
Steam
Tube
Rotary
Gas-fired
Energy Usage Factor
J/Hg Dry Product
(Btu/ton Dry Product)
7.3xlo! - 2.5x10?
(6.3xl05 - 8.4xl05)
A 9C
8.1x10° - l.lxltT
(6.9xl05 - 9.2xl05)
1.9X1099
(1.6xl06)
Ex1t,Gas Flow Rate Factor
dNnr/Mg Dry Product
(dscf/ton Dry Product)
587
(1.88 x ID4)
""
1340f
(4.3 x 104)
h
Exit Gas
Temperature
•c
(°F)
88°
(190)
120f
(250)
155
(310)
Exit Gas
Moisture
Content
Vol.*
40e
20-30
20-30
20-30
Mg of Dry .
Monohydrate Crystal Feed
Mg of Final
Sodium Carbonate Product
1.17
1.17
1.17
*The energy usage factor for steam tube equipment does not take Into account the efficiency of steam generation.
The energy usage factors for gas fired equipment 1s that which would be supplied by the gross heating value of
the fuel.
Assuming that all available Na2C03 In the dryer feed 1s recovered as final product.
cBased on mass and energy balances assuming a range 1n free water content of the feed of 5-15*.
dBased on measurement during source tests. (Reference 43.)
eBased on dryer design data.44 Source test data Indicate COX.
Based on source test data. (Reference 45.)
9Based on values calculated from a 1977 State Emission Inventory. (Reference 46-)
hHot reported due to 1ncons1stens1es In the raw data.
on values reported In Industry source test data (Reference 47).
-------
and an outlet gas moisture content of 40 percent. (Design data for
dryers at one plant specify an outlet moisture content of 30 to 50
percent.) The bases for the other factors in the table are given in
table footnotes.
Energy usage rates, material flow rates, and exit gas flow rates
for rotary steam tube, fluid bed steam tube, and rotary gas-fired dryers
producing 64 Mg/h (70 TPH) sodium carbonate are shown in Figure 3-12.
3.2.3 Predryers
3.2.3.1 General. In the direct carbonation process, rotary steam
heated predryers are used to lower the water content of wet sodium
bicarbonate crystals before they are calcined. The fact that predryers
do not dry the bicarbonate crystals to complete dryness is one of the
significant differences between predryers and dryers. Other significant
differences are in the physical construction and the operating conditions
of the equipment.
Predryers consist essentially of a rotating metal cylinder elevated
at the feed end to facilitate the flow of wet sodium bicarbonate toward
the discharge end. Ambient air preheated in steam tube heat exchangers
is admitted at the elevated end of the predryers. The air flows in a
cocurrent direction relative to the flow of the sodium bicarbonate.
This hot air transfers heat to the solids by convection, and as the
cooled air exhausts from the predryers, 1t carries out evaporated water.
Lifting flights along the inside of the predryers provide intimate
mixing between the wet sodium bicarbonate and the drying air.
Dissociation of sodium bicarbonate to sodium carbonate, carbon
dioxide, and water begins at about 50°C (120°F), and increases with
48
increasing temperature. The predryers are not designed for carbon
dioxide recovery; however, the calciners immediately downstream of the
predryers are designed for carbon dioxide recovery. (The carbon dioxide
recovered in the calciners is recycled to the brine carbonators.) Thus,
to avoid the loss of significant quantitites of carbon dioxide in the
predryers, they are operated at relatively low temperatures.
Quantitative values for the operating parameters and the emissions
for predryers are presented in Sections 3.2.3.2 and 3.2.3.3. These
3-38
-------
00
CO
to
Dry Monohydrate Crystals
from crystallizers
75 Mg/h (82 tph)
Energy (Steam)
10
4.7xlo;w - 6.3x10;" J/h
(4.4x10' - 5.9x10'° Btu/hr)
Ai
Dry Monohydrate Crystals
from crystallizers
75 Mg/h (82 tph)
Energy (Steam)
5.2X10!° - 6.9X1Q10 J/h
(4.8X107 - 6.5X107 Btu/hr)
Air-
Dry Monohydrate Crystals
from crystal lizers
75 Mg/h (82 tph)
Energy (Natural Gas)
1.2X1011 J/h
(1.1x10° Btu/hr)
Air-
Rotary
Steam Tube
Dryer
Fluid Bed
Steam Tube
Dryer
Rotary Gas-
Fired
Dryer
Dry Soda Ash Product
64 Mg/h (70 tph) Total
Exit Gas (40% moisture, 60% dry gas)
>624 dNm3/min
(21,900 dscfm)
1.9 - 2.2 Mg/h particulates
(2.1 - 2.4 tph) particulates
.Dry Soda Ash Product
>64 Mg/h (70 tph) Total
Exit Gas (20-30% moisture, 80-70% dry gas)
1430 dNm3/min
50,200 dscfm
3.2 - 8.2 Mg/h particulates
(3.6 - 9.0 tph) particulates
Dry Soda Ash Product
64 Mg/h (70 tph) Total
Exit Gas (20-30% moisture, 80-70% dry gas)
a
Figure 3-12. Material flow rates and energy usage rates for a dryer
in a plant using the monohydrate process
Insufficient information.
-------
values are based on design data and actual operating data taken during
EPA source tests at a direct carbonation sodium carbonate plant recently
brought on-stream. Operating personnel at this plant have found it
technically infeasible to operate the predryers at the design conditions
for certain of the operating parameters. Thus, the operating values for
these parameters observed during source tests were different from the
design values. However, plant personnel Indicated that the operating
conditions of the predryers had not yet been optimized. Thus, at some
time in the future plant personnel may perform optimization studies and
change the operating conditions of the predryers. If this Is done, the
new operating conditions may be different from both the design conditions
and the conditions observed during source tests.
3.2.3.2 Emissions. Particulates of sodium bicarbonate are the
primary type of emissions from predryers. Partlculate emission factors,
particulate concentrations, and exit gas flow factors for predryers are
presented in Table 3-9. Both design values and values measured during
EPA source tests are presented In this table.
Estimated uncontrolled particulate emission rates and exit gas flow
rates extrapolated from EPA source test data are presented 1n Table 3-10
for a predryer with a dry feed rate of 59 Mg/h (65 TPH). (Two predryers
of this size are expected for direct carbonation sodium carbonate plants
producing approximately 454,000 Mg/yr (500,000 TPY) of sodium carbonate
product.) The EPA test data are believed to be the best available data
for estimating normal uncontrolled particulate emissions even though
these data were taken at a plant where operating conditions were not yet
optimized. As mentioned in Section 3.2.3.1, plant personnel found it
technically infeasible to operate at the design values for certain para-
meter; the gas flow rate was one such parameter.
The lower particulate loading in the exhaust gases from predryers
relative to dryers (Section 3.2.2.2) is partially due to the difference
in the amount of drying which 1s done 1n these units. The product from
dryers is essentially free of moisture, while the product from predryers
contains significant amounts of moisture. Thus, there Is a zone of dry
3-40
-------
TABLE 3-9. UNCONTROLLED EMISSION PARAMETERS FOR PREDRYERS IN THE DIRECT CARBONATION PROCESS
Source of Data
EPA Test Datac
EPA Test Datac
Design Data
Particulate Emission Factor
kg/Mg dry
feed3
1.12
0.499
0.419
0.855
3,15
3.21
27
Ib/ton dry
feed3
2.24
0.998
0.838
1.71
6.29
6.42
55
Particulat? Concentration
g/dNm3
0.620
0.281
0.261
0.483
1.49
1.43
10
gr/dscf
0.271
0.123
0.114
0.211
0.653
0.625
4.4
Exit Gas Flow Factor
dNm3/Mg
dry feld
1800
1770
1610
1770
2110
2240
2700
dscf/ton
dry feed3'6
57800
56800
51500
56800
67400
71900
86000
u>
I
ava1ues are reported in terms of pure dry feed as sodium bicarbonate. Approximate free water
content and impurity content of the sodium bicarbonate feed are reported in Table 3-11.
Curing the time that the EPA test data were obtained, plant operators were not varying the
gas flow rate even though the feed rate of bicarbonate crystals was variable. The differences
in the exit gas flow factors obtained from EPA test data are due primarily to differences in the
feed rate of bicarbonate crystals rather than differences in the gas flow rate.
Reference 49
Reference 50
-------
TABLE 3-10. UNCONTROLLED PARTICULATE EMISSIONS FROM PREDRYERS
IN THE DIRECT CARBONATION PROCESS
(Extrapolated from EPA Test Data)3
Feed Rateb
flfl!)
59
(65)
Participate Emission
Factorb
kg/Mg feed
(Ib/ton feed)
0.377-3.21
(0.754-6.42)
Parti cul ate Emission
Rate
kg/h
(lb/h)
22.2 - 189
(49.0 - 417)
Participate
Concentration
g/dNm
(gr/ds.cf)
0.261 -1.49
(0.114-0,653)
Exit Gas Flow Rate
d/Nm /min
(dsef/min)
1400-2400
(46000-780001
CO
I
ro
Reference 51
Reported as dry impure sodium bicarbonate feed. The impurity content ranges from 0 to 10%,
-------
material near the discharge end of dryers; however, the material through-
out predryers is moist. Moisture increases the surface tension between
crystals, and this increased surface tension suppresses dusting.
Particulate emissions from predryers are affected by gas velocity
and the particle size distribution of the feed. Gas velocity through
the predryer affects the degree of turbulence and agitation. As the gas
velocity increases, the rate of increase in the total emission rate of
particulates increases. (Not enough information is available to define
the effect on particulate concentration). Particle size distribution of
the feed affects particulate emissions because small particles are more
easily entrained in a moving stream of gas than are larger particles.
Particle size distribution of emissions from predryers measured in
EPA source tests are presented in Figure 3-13.
3.2.3.3 Mass and Energy Balances. Values for mass and energy
balances on predryers are presented in Table 3-11. In most cases, a
range which includes design values and values obtained or calculated
from data taken during EPA source tests is reported. The range of
values reported for the exit gas flow factor is based on EPA source
test data only, since, as discussed in Section 3.2.3.2, these data are
believed to be more representative than design data of how predryers
will normally operate.
Energy usage rate, material flow rates, and exit gas flow rate for
a predryer with a capacity of 59 Mg/hr (65 TPH) of dry bicarbonate feed
are indicated in Figure 3-14. Values indicated in Figure 3-14 are based
on values presented in Table 3-11.
3.2.4 Bleachers
3.2.4.1 General. In the direct carbonation process, impure sodium
carbonate from the calciners is bleached with sodium nitrate to burn off
discoloring impurities. These impurities consist mostly of carbonaceous
organics.
The bleaching operation is carried out in a rotary gas-fired unit
similar to the gas-fired dryer described in Section 3.2.2.1.2 and pictured
in Figure 3-9. Feed is introduced at the elevated end and flows counter-
currently to the hot combustion gases. Lifting flights along the
3-43
-------
10...
99 99 99 9 99 8
99 98 95 90
0.5 0.2 0.1 005 0.01
-.10
CO
I
O.
Q
Predryer #2 Test 1
Predryer #2 Test 2
O Predryer #2 Test 3
20 S5 40 50 60 70 80
0.01 0.03 O.I 02 0.5
Cumulative Percent by Weight less than
-------
TABLE 3-11. VALUES FOR MASS AND ENERGY BALANCES ON PREDRYERS
Parameter
Value
Energy Usage Factor
J/Mg Dry Feed
(Btu/Ton Dry Feed)
Exit Gas Flow Factor
dNm /Mg Dry Feed
(dsef/Ton Dry Feed)
3' )C
C'd
Exit Gas Moisture Content
Vol %
Exit Gas Temperature
°C
Moisture Content of Bicarbonate
Crystal Feeda'f
Moisture Content of Bicarbonate
Crystals from the Predryer *
Ma of Dry Bicarbonate Crystal Feed0*6
Mg of Final Sodium Carbonate Product
Impurity Content of the Bicarbonate
Crystal Feed9 %
1.5 x
- 5.8 x
1.3 x KT - 5.1 x 10'
1.4 x 10* -
(4.2 x HT
2.4 x w
7.2 x 1(T)
4-10
38 - 57
(100 - 135)
6-16
5-15
1.8 - 2.0
The reported range includes design values and values obtained or calculated
from data taken during EPA source tests.
The energy usage factor does not take into account the efficiency of steam
generation equipment.
°Based on impure dry feed as sodium bicarbonate.
Based on values obtained during EPA source tests.
eBased on the assumption that 90 percent of the available sodium carbonate
in the predryer feed is recovered as final sodium carbonate product.
Wet basis
9Dry basis. The design value is within this range.
3-45
-------
CO
Wet sodium bicarbonate feed
4-11 Mg/h (4-12 TPH) water
<5.9 Mg/h (<6.5 TPH) impurities
53-59 Mg/h (58-65 TPH) sodium bicarbonate
Energy (Steam)
8.0 x 109
(8.5 x 10° - 3.3 x 10' Btu/h)
Air-
3.4 x 1010 J/h
Rotary Steam
Heated
Predryer
Figure 3-14 Material flow rates and energy usage rates
for predryers in a plant using the direct
carbonation process.
•Wet sodium bicarbonate
to the crystallizers
3-10 Mg/h (3-11 TPH) water
<5.9 Mg/h (* 6.5 TPH) impurities
53-59 Mg/h (58-65 TPH) sodium
bicarbonate
•Exit Gas (4-10% water,
90-96% dry gas)
8.4 x 104 - 1.4 x 105
^6 - •• x 106 dscf/h)
dNm3/h
(2.8 x 10W - 4.7
Particulates
22.2 - 189 kg/h (49.0 - 417 Ib/h)
There are two predryers in a train.
-------
inside of the bleacher aid the movement of the solids and provide inti-
mate mixing with the combustion gases. The operating temperature of
bleachers is reported to be approximately 450°C (850°F).
Quantitative values for other operating parameters and the emissions
for bleachers are presented in Sections 3.2.4.2 and 3.2.4.3. These
values are based on design data and actual operating data taken during
EPA source tests at a direct carbonation sodium carbonate plant recently
brought on-stream. The operating data taken during the source tests
were in close agreement with the design values.
3.2.4.2 Emissions. Emissions from bleachers consist mainly of
particulates of sodium carbonate. Small amounts of compounds formed
from the reactions of sodium nitrate may also be present in the particu-
lates.
Particulate emission factors, particulate concentrations, and exit
gas flow factors for bleachers measured during EPA source tests are
presented in Table 3-12. Design values are also presented. The design
value for the particulate emission factor is lower than any of the
values measured during the source tests. However, it is only slightly
lower than the lowest measured value.
Particle size distributions for emissions from bleachers measured
during EPA source tests are presented in Figure 3-15.
Estimated uncontrolled particulate emission rates and exit gas flow
rates extrapolated from source test data are presented in Table 3-13 for
a bleacher with a feed rate of 82 Mg/hr (90 TPH). (This size bleacher
is expected for a direct carbonation plant producing approximately
454,000 Mg/yr (500,000 TPY) of sodium carbonate product.)
Particulate emissions from bleachers are affected by gas velocity
and the particle size distribution of the feed. Gas velocity through the
bleacher affects the degree of turbulence and agitation. As the gas
velocity increase, the rate of increase in the total emission rate of
particulates increases. (Not enough information is available to define
the effect on particulate concentration.) Particle size distribution
of the feed affects particulate emissions because small particles are
more easily entrained in a moving stream of gas than are larger particles.
3-47
-------
TABLE 3-12. UNCONTROLLED EMISSION PARAMETERS FOR BLEACHERS IN THE DIRECT CARBONATION PROCESS
Source of Data
EPA Test Datab
EPA Test Datab
Design Data
Parti cul ate Emission Factor
kg/Mg drya
feed
228
161
185
152
53.5
34.5
Ib/ton dry3
feed
455
321
369
.
303
106
68.9
Parti cul ate Concentration
g/dNm3
380
297
307
.
277
105
70
gr/dscf
166
130
134
—
121
46
30
Exit Gas Flow Factor
dNm3/Mg
dry feed
598
536
601
—
548
508
512
dscf/ton
dry feed
19200
17200
19300
_
17600
16300
16400
CO
4*
00
Values were measured and are reported in terms of dry. pure feed as sodium carbonate, to the
predryers. A one hour process lag time between the predryer feed point and the bleacher feed
point was assumed. The actual feed to the bleachers is impure sodium carbonate with an impurity
content of less than 15 percent.
Reference 52
-------
CO
-t»
10
Q.
O
10
I
O
N
•r*
CO
0)
10..
9...
8...
7...
99.99 99.9 99.6
9998 95 90 80 70 6O 50 40 30 20
10
2 1 0.5 0.2 0.1 0.05 0.01
a=3aczB3333;;iiB;:3i=3:3=5==ais::i:3:=;c=========:;r=3t;;=3e=—-=—!•:;-•-=—
i=dE^
t
-.10
...9
...B
7
4
Figure 3-15
Particle Size Analysis
Bleachers
Plant E
Bleacher #1 Test 1
ABleacher #1 Test 2
ED Bleacher #2 Test 1
Bleacher #2 Test 2
rrrrt-JTtn
20 30 40 50 60 70 80
0.01 005 01 0.2 0.5
Cumulative Percent by Weight less than (Dp)
-------
TABLE 3-13- UNCONTROLLED PARTICULATE EMISSIONS FROM BLEACHERS IN THE DIRECT
CARBONATION PROCESS
(Extrapolated from EPA data)a
Feed Rateb
Mg/h
(ton/h)
82
(90)
Parti cul ate. Emission
Factorb
kg/Mg feed
(Ib/ton feed)
45.5 - 228
(90.1 - 455)
Participate Emission
Rate
kg/h
(lb/h)
3700 - 19000
(8100 -r 41000)
Parti cul ate
Concentration
q/dNm3
(g/dscf)
105 - 380
(46 - 166)
Exit Gas Flow Rate
dNm /min
(dscf/min)
590 - 820
(21000 - 29000)
00
I
en
O
Reference 53
Values are reported in terms of dry impure sodium carbonate feed to the bleachers
content ranges from 0 to 15%.
The impurity
-------
The exit gas flow rate for bleachers is lower than that for gas-
fired calciners or gas-fired dryers. This lower flow rate results from
a lower energy requirement.
Sensible heat is the only significant energy requirement in the
bleaching operation. However, in calcining and drying the sensible heat
requirement is minor relative to the energy required to drive the endo-
thermic reactions in these operations. Since the sensible heat require-
ment in bleaching is only about twice as great as the sensible heat
requirement in either calcining or drying, the total energy requirements
for bleaching are less than they are for either calcining or drying.
Since less fuel is required, less combustion gas is generated.
3.2.4.3 Mass and Energy Balances. Values for mass and energy
balances on bleachers are presented in Table 3-14. In most cases, a
range which includes design values and values obtained or calculated
from data taken during EPA source tests is reported. As discussed
briefly in Section 3.2.4, there was generally close agreement between
the design values and the values based on actual data taken during
source tests.
Energy usage rate, material flow rates, and exit gas flow rate for
a bleacher with a capacity of 85 Mg/h (90 TPH) of feed are presented in
Figure 3-16. Values indicated in Figure 3-16 are based on values presented
in Table 3-14.
3.3 BASELINE EMISSIONS
As noted in Section 3.1, all plants producing sodium carbonate by
the monohydrate process are located in Wyoming and all direct carbonation
plants are in California. All future plants are also expected to be
located in these states. Thus, the emission regulations of these two
states will be used to define the baseline emission level in this study
for these respective plants.
Several regulations limiting particulate emission rates are applica-
ble to sodium carbonate plants in Wyoming. The maximum emission rate
that would be allowed by the Wyoming Department of Environmental Quality
is given by a process weight regulation, as follows:
3-51
-------
TABLE 3-14. VALUES FOR MASS AND ENERGY BALANCES ON BLEACHERS
Parameter
Value
Energy Usage Factor3' 'c
J/Mg Feed
(Btu/ton Feed)
Exit Gas Flow Factor0»d
dNm3/Mg Feed
(dscf/ton Feed)
Exit Gas Moisture Content3
Vol %
Exit Gas Temperature3
°C
(°F)
Mg of Feedc>e
Mg of Final Sodium Carbonate Product
Impurity Content of the Feed
4 x 108 - 5 x 108
3 x 105 - 4 x 105
430 - 600
1.4 x 104 - 1.9 x 104
4 - 8
163 - 204
(325 - 400)
1.1 - 1.3
aThe reported range includes design values and values obtained or calculated
from data taken during EPA source tests.
The energy usage factors represent the energy which must be supplied by the
gross heating value of the fuel.
cBased on impure dry feed as sodium carbonate.
Based on values obtained during EPA source tests.
eBased on the assumption that 90 percent of the available sodium carbonate
in the bleacher feed is recovered as final sodium carbonate product.
3-52
-------
CO
CJ1
CO
Feed from the Calciners
70-82 Mg/h (77-90 TPH) sodium carbonate
<12 Mg/h (<13 TPH) impurities
Energy (Natural Gas)
3.3 x 1010 - 4.1 x 1010 J/h
(2.7 x 107 - 3.6 x 107 Btu/h)
Air
Gas-Fired
Rotary
Bleacher
Bleached Sodium Carbonate to
the Crystallizers
70-82 Mg/h (77-90 TPH) sodium
carbonate
^12Mg/h (<13 TPH) impurities
Exit Gas.(4-8% water. 92-96% dry gas)
3.5 x 10V 4.9 x 10* dftar/h
(1.3 x 10b - 1.7 x 106 dscf/h)
Particulates
3700 - 19000 kg/h (8100-41000 Ib/h)
Figure 3-16 Material flow rates for a bleacher
in a plant using the direct carbonation process.
-------
Allowable particulate emissions (Ib/hr) = 17.31 X0'16
Where X - Process weight (tons per hour).
For coal-fired calciners, process weight includes the coal. This equation
would be applied to each unit of process equipment.
However, a majority of the sources in the Wyoming sodium carbonate
plants are controlled to more stringent levels than required by this
process weight regulation. Under proposed Wyoming SIP revisions, the
use of "BACT" is required for approval of permits for new plants and
expansions. The emission level corresponding to BACT is determined by
the State of Wyoming on a case by case basis. For large sources (such
as calciners) it is generally close to the process weight limitation,
but for smaller sources (such as dryers) the BACT requirement is generally
more stringent than process weight. This strict level is imposed to
3
achieve and maintain an ambient particulate standard of 60 ug/m . The area
where three of the four sodium carbonate plants in Wyoming are located has
been found to be in non-compliance with this standard and with the
56
National Ambient Air Quality Standards for Particulates.
Wyoming BACT levels are not set by law, but are determined on a case by
case basis. Therefore, new plants may be subjected to a less stringent
definition of BACT than existing plants. The most representative baseline
emission level for this study would be in between the level based on the process
weight regulation and the BACT level as defined for the most recently con-
structed plant. The level based on the process weight regulation will be used
to analyze the control costs and economic impact of the regulatory alternatives,
since it will yield a higher incremental control cost than the BACT level.
Both levels will be used to project a range of emission reduction due to the
regulatory alternatives.
The direct carbonation plants are in the San Bernardino County Air
Quality District of California, which recently separated from the South
Coast Air Quality Management District (SCAQMD) and applies most of the
SCAQMD regulations. Under these regulations, sodium carbonate plants
are subject to mass emission limitations according to process weight and
3-54
-------
to concentration limitations based on exit gas flow rate.58 The allowable
concentrations and mass emission rates are given in Tables 3-15 and 3-16.
Since sodium carbonate plants must comply with both of these limitations,
the more stringent of the two is considered as the baseline emission
level for direct carbonation plants. For predryers, process weight
gives the stricter emission limit, but for bleachers and product dryers,
the concentration limit is more stringent.
Emission rates that would be allowed under the applicable regulations
for each piece of equipment for the equipment sizes considered for a
model sodium carbonate plant are presented in Table 3-17. These emission
rates represent the baseline emission levels for this study.
3-55
-------
:A6LE 3-15. MAXIMUM ALLOWABLE PARTICULATE CONCENTRATIONS FOR CALIFORNIA
59
m» m .-•».-
25 JJ.
30
35
40
45
50
60
70
ao
90
100
125
150
175
200
250
300
350
400
*50
500
600
TOO
800
ZsJfiHd.
883 1^l
1059
1236
1*13
1589
1766
2115
2*72
2825
3178
3531
4414
5297
6180
7063
8829
10590
12360
14130
15890
17660
21190
24720
20250
361
3*7
32*
306
291
279
267
246
230
217
190
177
167
159
152
146
137
129
123
.158
•152
.141
.13*
.127
.122
.117
.107
.100
•09*7
.0900
•0830
•0773
•0730
.0694
.0664
.0637
.0598
.0563
•0537
1000
1100
1200
1300
1400
1500
1750
3000
4000
5000
6000
8000
10000
15000
25000
40000
50000
70000
or
31780
35310
49440
52970
61800
70630
79460
118
113
109
106
102
100
97
105900
141300
176600
211900
353100
529700
706300-
1059000
1413000
1766000
2472000
or acre
87
83
80
75
67
62
58
52
48
41
37
3*
32
28
26
23
0.0515
.0493
.0476
.0463
.0445
•0*37
.0402
•0380
.0362
.0349
•0327
•O293
•0271
.0253
.0227
.0210
.0179
.0162
.0148
.0140
.0122
.0100
3-56
-------
TABLE 3-15. MAXIMUM ALLOWABLE SOLID PARTICuL^TE EMISSION
FCP c^
^^
too ^r
150
200
250
3W
350
too
*50
500
600
TOO
800
900
1000
1250
1500
1750
2000
2250
2500
2750
3000
3250
3500
4000
4500
5000
6000
7000
8000
«« !!____
*
220 i2L
331
441
551
661
772
882
992
1102 .
1323
15*3
1764
1984
2205
2756
3307
3958
4409
4960
5512
6063
661*
7165
7716
8016
9921
11020
13230
15430
176*0
MUCbHM D&M^URBft BfttA
AlleMd far 3oU6 Fmr-
ti«alrt« •KttorgtBr*-
ttta HI ••hai'Md !*•• „
ZU pednt« offnini*)
fl, - Tfnl -
0.450
0.585
0.703
o.ao4
0.897
0.983
1.063
1.138
1.209
1.310
1.461
1.573
1.678
1.777
2.003
2.206
2.392
2.56>
2.723
2.87*
3^16
3-151
3^80
3-*0*
3^37
3^55
4U)59
4.434
4.775
5.089
•**•
0.99
1.29
1.55
1.77
1.98
2.17
2.34
2.51
2.67
2.95
3^2
3>7
3-70
3-92
4.42
*^6
5.27
5^5
6j»
6.3*
6^5
6.95
7.23
7.50
8.02
8.50
8.95
9-78
10.5
11^2
PilJUH tfcilfrt
^ ft^^M^
9000
10000
12500
15000
17500
20000
25000
^tBOOQ
^**^***
35000
4OOOO
45000
50000
oOOOO
70000
80000
90000
100000
125000
150000
175000
200000
225000
250000
275000
300000
325000
350000
400000
450000
500000
OF BOTV
» — it .
19840
22050
27560
33070
39580
44090
55120
66140
77160
88180
99210
110200
132300
15*300
176*00
198400
220500
275600
3307OU
395800
440900
496000
551200
606300
661400
716500
7Y1600
881800
992100
1102000
or norv
mxiMm DUeaarfc* Nat*
LiieM»4 for Solid P>z*»
UMlAt* M»tt«rU««-
nt« OtMterndnroB
En poiat* of hun»<)
5.308
5.440
5.732
S982
6^02
6.399
6.7*3
7.037
7^96
7.527
7-738
7.931
8.277
8.582
8^5*
9*102
9.329
9.830
10^6
10^*
10.97
11.28
11.56
11.82
12.07
12.30
12.51
-2.91
'.3.27
13.60
i
1
11.7
12«0
12^
13^
13-7
1*.1
i*.9
15.5
16.1
16.6
17.1
17.5
18.2
18.9
19.5
20.1
20.6
21.7
22.6
23-5
2*.2
24.9
25.5
26.1
26.6
27.1
27.6
28.5
29O
30.0
2-57
-------
TABLE 3-17. BASELINE EMISSION LEVELS FOR MODEL
SODIUM CARBONATE PLANTS
1
Facility
Coal -fired Calciners
Rotary Steam Tube
Dryer
Fluid Bed
Steam Tube Dryer
Predryer
Feed Rate
Mg/h (TPH)
127 (140)b
83 (91)c
83 (91)c
59 (65)f
Bleacher j 82 (90)
i
Allowable
Emission Rate3
kg/h (Ib/h)
9.2 (20.3)-17.3 (38.2)
4.7 (10.4H5.9 (35.0)d0
5.08 (11.2)e
4.7 (10.4)-15.9 (35.0)
8.2 (18.2)
4.90 (10.8)
aLower value represents BACT as defined for Tenneco plant; upper value
represents process weight regulation.
Includes 9 Mg/h (10TPH) coal.
cDry monohydrate crystals.
For monohydrate process (Wyoming).
Q
For direct carbonation process (California).
Dry weight.
3-58
-------
3.4 REFERENCES FOR CHAPTER 3
1. Foster, Russell J., "Sodium Carbonate", Mineral Commodity Summaries
1979, pp. 148-149.
2. Staff of the U.S. Bureau of Mines, "Sodium and Sodium Compounds",
Bureau of Mines Minerals Yearbook,various yearly editions from 1948
through 1976.
3. Reference 1.
4. Telecon, Secrest, A., Radian Corp., with Jack Rourke, Allied Chemical
Co., Syracuse Plant, March 27, 1979.
5. Telecon. Secrest, A., Radian Corporation, with George Kanelis, Allied
Chemical Corporation. September 12, 1979.
6. Reference 5.
7. Telecon. Sipes, T.G., Radian Corporation, with Russell Foster, U.S.
Bureau of Mines. March 1, 1979.
8. Blythe, G.M., Sawyer, J.W., Trede, K.N., "Screening Study to Determine
Need for Standards of Performance for the Sodium Carbonate Industry",
Radian Corp., DCN 78-200-187-34-08, p. 35.
9. Telecon. Secrest, A., Radian Corporation with Russell Foster, U.S.
Bureau of Mines. March 23, 1979.
10. Staff of the U.S. Bureau of Mines, Division of Nonmetallic Minerals,
"Sodium Compounds in 1978", Mineral Industry Surveys, Annual
Preliminary.
11. Reference 8, pages 5-9 and 15-26.
12. Parkinson, Gerald, "Kerr-McGee expands soda ash output nine-fold from
Searles Lake brines", E/MJ, October 1977, p. 74.
13. Wyoming Department of Environmental Quality, Division of Air
Quality. Wyoming 1979 Implementation Plan for Sweetwater County
Nonattainment Area. Undated.
14. Reference 12, p. 71.
15. Mark, H. F., et al., editors, "Sodium Carbonate", Kirk-Othmer Encyclo-
pedia of Chemical Technology, Volume 1. 2nd edition. New York: Wiley,
1969, p. 464.
3-59
-------
16. Environmental Protection Agency, Emission Measurement Branch. Emission
Test Program: Sodium Carbonate Manufacturing'PIant Conducted At
Texasgulf, Inc. August 1, 1979, EMB Report 79-SOD-l.
17. Environmental Protection Agency, Emission Measurement Branch. Emission
Test Program: Sodium Carbonate Manufacturing Plant Conducted at FMC
Corporation. March 11, 1980. EMB Report 79-SOD-2.
18. Wyoming Department of Environmental Quality, Division of Air Quality.
Particulate Stack Sampling Reports for Allied, FMC, Stauffer, and
Texasgulf Sodium Carbonate Plants.
19. Reference 16.
20. Reference 17.
21. Compilation of Air Pollutant Emission Factors, 2nd Edition, U.S. EPA,
QAQPS, February 1976, p, 1.1-3.
22. Trip Report. FMC Corporation - Industrial Chemical Division, Green
River, Wyoming. February 21, 1979. Prepared by T. G. Sipes, Radian
Corporation.
23. Telecon. Sipes, T. G., Radian Corporation with W. F. Stocker, Allied
Chemical Corporation. March 20, 21, 26, 1979. Operation of and
emissions from Allied Chemical's Sodium Carbonate Plant in Green River,
Wyomi ng.
24. Reference 8, page 39.
25. Reference 16.
26. Reference 17.
27. Reference 16.
28. Reference 17.
29. Wyoming Department of Environmental Quality, Division of Air Quality.
1977 Emission Inventories for Allied, FMC, Stauffer, and Texasgulf
Sodium Carbonate Plants.
30. Reference 22.
31. Reference 23.
32. Trip Report. Texasgulf, Inc., Granger, Wyoming. February 15, 1979.
Prepared by T. G. Sipes, Radian Corporation.
3-60
-------
33. Perry, Robert H. and Cecil H. Chllton. Chemical Engineering Handbook,
5th ed. New York: McGraw-Hill, 1973. p. 20-42.
34. Environmental Protection Agency, Office of Air Quality Planning and
Standards, Research Triangle Park, North Carolina. Phosphate Rock
Plants. Draft Report. September 1978.
35. McCabe, Warren L., and Julian C. Smith. Unit Operations of Chemical
Engineering. New York: McGraw-Hill, 1976. p. 779.
36. Reference 22.
37. Reference 16.
38. Confidential information submitted by industry.
39. Reference 18.
40. Reference 16.
41. Confidential information submitted by industry.
42. Reference 23.
43. Reference 16.
44. Reference 23.
45. Confidential information submitted by industry.
46. Reference 29.
47. Reference 18.
48. Mark, H.F., et al.', editors. "Sodium Carbonate", Kirk-Othmer Encyclope-
dia of Chemical Technology, Volume 18, 2nd edition, New York: Wiley,
1969. p. 467.
49. Environmental Protection Agency, Emission Measurement Branch,
Particulate Emissions from the Kerr-McGee Corporation Sodium Carbonate
Plant, Trona, Calif., March 14, 1980, EMB Report 79-SOD-3
50. Trip Report. Kerr-Mcbee Chemical Corporation, Trona, California.
February 20, 1979. Prepared by T. G. Sipes, Radian Corporation.
51. Reference 49.
52. Reference 49.
53. Reference 49.
54. Environmental Reporter 556:0510, Wyoming Regulations.
55. Telecon. Sipes, T. G., Radian Corporation and Charles Collins.
Wyoming Department of Environmental Quality. March 25, 1979 and
April 10, 1979.
3-61
-------
56. Reference 13.
57. Reference 8.
58. South Coast Air Quality Management District. Rules and Regulations
of the South Coast Air Quality Management District, El Monte,
California. 1977.
59. Reference 58.
60. Reference 58.
3-62
-------
4. EMISSION CONTROL TECHNIQUES
Techniques suitable for controlling particulate emissions from
calciners, dryers, predryers, and bleachers in sodium carbonate plants
are discussed in this chapter. A general description of the applicable
emission control techniques is given in Section 4.1, along with a
discussion of significant design variables and factors affecting per-
formance. Application of these control techniques to sources in the
sodium carbonate industry is discussed in Section 4.2. The performances
that have been demonstrated for each control device on sources in the
sodium carbonate industry are presented in Section 4.3.
4.1 DESCRIPTION OF CONTROL TECHNIQUES
Particulate emission control techniques which may be applicable to
sources in sodium carbonate plants include the following:
centrifugal separation,
wet scrubbing,
electrostatic precipitation, and
fabric filtration.
These techniques are described in this section. Factors affecting the
applicability of these techniques to calciners, dryers, predryers, and
bleachers are discussed in Section 4.2.
4.1.1 Centrifugal Separation
Centrifugal separators, or cyclones, rely on centrifugal forces to
effect particulate separation from the gas stream. Cyclones are fre-
quently used upstream of a scrubber or electrostatic precipitator.
4.1.1.1 Basic Description. A typical cyclone is illustrated in
Figure 4-1. Dust-laden gases enter a conical-shaped vessel tangentially
or axially and leave through a central opening. As the gas flows in
4-1
-------
GAS OUTLET
GAS INLET-
SECTION A-A
COLLECTED
DUST
70-1729-1
CYCLONE
Figure 4-1. Conventional centrifugal separator (cyclone)
4-2
-------
a vortex down through the cyclone, the inertia of the particles causes
them to move outward across the gas streamlines towards the cyclone
shell. As the vortex is reversed in the conical portion of the cyclone,
most of the particles continue to cyclone downward along the outer shell
into a receiving chamber.
4.1.1.2 Factors Affecting Performance. The most important variables
in the design of a cyclone are the cyclone dimensions. Small diameter
cyclones have greater removal efficiencies and higher pressure drops due
to the greater angular velocity (or inertia) of the gas stream and entrained
particles. Banks of small-diameter cyclones in parallel, with common gas
inlets and outlets, are frequently used to achieve higher efficiencies.
Long cyclones have greater removal efficiencies than short cyclones due
to the increased time in which particles are subject to separating forces.
Cyclone pressure drops typically range from 5 to 15 cm (2 to 6 inches) of
water.
Cyclone efficiency is highly dependent on the size of the particu-
lates being collected: large particles are collected more efficiently.
For example, a high efficiency cyclone may remove 95-99 percent of parti-
cles greater than 40u, 90-99 percent of particles from 15-50u, 80-90
percent of particles from 5-20u, and only 50-80 percent of particles less
than 5u. Typical cyclone overall efficiencies range from about 55 to 95
percent.
Various factors limit the effectiveness of cyclonic collectors. If
the cyclone is designed for peak efficiency at peak flow, lower efficiencies
will be achieved during lower flows due to the reduced gas velocity in
the cyclone. Similarly, temperature decreases may reduce removal efficiency
by increasing the viscosity and density of the gas. In-leakage of air
through the dust removal system may reduce the overall collection efficiency
by re-entraining dust. Additional re-entrainment can result if the dust
is not adequately removed from the receiving chamber.
4.1.2 Wet Scrubbing
4.1.2.1 Basic Description2 Scrubbers rely mainly on inertia! impac-
tion of particulates with water droplets to effect particulate separation
4-3
-------
from the gas stream. Farcies are contacted with, a wetted surface or
atomized liquid droplets. Although gas streams will diverge to pass such
obstructions, the inertia of particles in the gas stream will carry the
particles into the water droplets or wetted surface. The particulate
laden liquid is then separated from the gas stream, and either recycled
to the production process or discharged as waste.
Scrubbers are usually classified by energy consumption (in terms of
gas-phase pressure drop). Low-energy scrubbers, represented by spray
chambers and towers, have pressure drops less than 1.3 kPa (5" of water).
Medium-energy scrubbers such as centrifugal scrubbers have pressure
drops of 1.3-3.7 kPa (5-15" of water). High-energy scrubbers such as
venturi scrubbers have pressure drops exceeding 3.7 kPa (15" of water).
Because the efficiency of particle removal is largely proportional to
the pressure drop, venturi scrubbers have been favored by sodium carbon-
ate producers needing high removals of particulates.
A typical venturi scrubber is shown in Figure 4-2. Scrubbing
liquid is injected into the gas stream and cascades by gravity and
velocity pressures towards the venturi throat. In the high turbulence
zone associated with the venturi throat, particulates collide with and
are collected by the atomized liquid droplets. The liquid is subse-
quently separated from the gas in a cyclonic separator usually equipped
with a mist eliminator. Higher scrubber pressure drops are achieved by
narrowing the venturi throat.
4.1.2.2 Factors Affecting Performance. The design of a scrubber
depends on the characteristics of the dust being collected and the gas
being cleaned. The most important particle characteristics are particle
size distribution, particulate loading, and physical and chemical prop-
erties of the particulate and gas.
Larger particles are removed more efficiently than small ones, as
indicated in Figure 4-3. The principal factors affecting the performance
of venturi scrubbers are the operating pressure drop across the scrubber,
4.4
-------
CLEAN GAS
OUTLET
1
DIRTY GAS
INLET
LIQUOR INLETS
ALTERNATE
LIQUOR INLETS
FLOODED ELBOW
CYCLONIC
SEPARATOR
TANGENTIAL INLET
LIQUOR OUTLET
70-1728-1
Figure 4-2. View of a venturi scrubber with centrifugal separator chamber
4-5
-------
COLLECTION EFFICIENCY VS PARTICLE SIZE
o
UJ
o
UJ
o
ii-
ii.
UJ
o
o
0.5
1.0
2.0
PARTICLE DIAMETER IN MICRONS
99.99
99.95
99.90
99.80
99.50
99.00
9800
95.00
90.00
80.00
50
100
Figure 4-3. Vendor venturi scrubber comparative fractional
efficiency curves.
4-6
-------
the liquid to gas ratio, the water/gas separation achieved in the
separator, and the scrubber liquor saturation level. As shown in Figure
4-3, higher removal efficiencies are achieved with scrubbers operated at
higher gas-phase pressure drops. Similarly, higher removals are achieved
at higher liquid to gas ratios. However, there is a practical upper
limit on these parameters, depending on the effectiveness of gas/liquid
separation. Overall particulate removal efficiency is reduced if the
downstream mist eliminator is unable to separate finely-atomized water
droplets from the exit gas. These uncoilected droplets evaporate and
release their particulate contents to the air.
4.1.3 Electrostatic Precipitation4'5
4.1.3.1 Basic Description. The collection of particulates by
electrostatic precipitation involves five basic steps:
the generation of an electric field (or corona) around
a high tension wire,
the ionization of gas molecules by the corona,
the charging of particulates by ionized gas molecules
near the wire,
the migration of the charged particulates to oppositely
charged collecting electrodes, and
the removal of the charged particles.
A typical electrostatic precipitator is pictured in Figure 4-4.
The corona is generated by the application of a high voltage to a
discharge electrode system consisting of rows of vertical wires. The
strength of the corona depends in part on the gas composition. The
charging of particles depends on local conditions in the electrostatic
precipitator (ESP) such as strength of the corona and on the character-
istics of the particles. The subsequent migration of the charged par-
ticles to the collecting plates depends on the particle size, resis-
tivity, gas velocity and distribution, rapping, and field strength.
The collecting electrodes are rigid plates that are baffled.
Electromagnetic or pneumatic hammers are used to rap the electrodes,
dislodging the collected dust which then falls into hoppers. Baffling
on the collecting electrodes provides shielded air pockets that reduce
re-entrainment of particles after rapping.
4-7
-------
5 Ripper System
cotodmg plates
. t 4 Srvoudcd
discharge
electrodes
2 Collectng
pl«tt
6. Hopper baffle pUi*
Figure
viev/ of a typical electrostatic precipitator
4-8
-------
The suitability of participate collection by electrostatic precipi-
tation depends on the resistivity of the particles. Participates with
3 10
resistivities in the range of 5 X 10 to 2 X 10 ohm-cm have been shown
4
by experience to be the most suitable for electrostatic precipitation.
Particles with lower resistivities will give up their charge too easily
and will be re-entrained in the gas stream. Particles with higher
resistivities will coat the collecting plates and will be hard to dis-
lodge. The coated plates will thus have diminished ability to attract
charged particles.
4.1.3.2 Factors Affecting Performance. The key design variable
for electrostatic precipitator design is the area of the collecting
plate. The overall removal efficiency of the ESP can then be defined by
the plate area, migration (or drift) velocity, and gas flow rate according
to the Deutsch-Anderson equation:
-WA
n = 1 - e ~OT
where n = removal efficiency
Q = gas flow rate
W = migration velocity
A = collecting plate area.
As indicated by this equation, ESP efficiency increases with increasing
plate area relative to gas flow rate and with increasing migration
velocity.
Another key design variable is proper determination of the rapping
cycle. If the cycle is too short, material that collects on the collect-
ing plates will not be thick enough to settle to the bottom of the
precipitation chamber and will be re-entrained. This re-entrainment of
collected particulates can be minimized by proper design of collecting
electrodes and rappers, minimizing rapping, and rapping only a small
section at a time. If the rapping cycle is too long, however, the
material on the collecting plates will become too thick and collection
efficiency will be reduced.
Other design parameters that affect ESP performance include plate
spacing and type, plate height and length, applied voltage, corona
4-9
-------
strength, residence time, and transformer/rectifier configuration. ESP's
typically have gas-phase pressure drops less than 1.3 cm (0.5 in.)
of water.
Gas flow distribution also has a strong impact on ESP efficiency.
Poor flow distribution results in variations in the extent of gas
treatment. In addition, high velocities in the vicinity of hoppers and
collecting electrodes can result in re-entrainment of collected dust.
These effects of poor gas flow distribution cause a drop in ESP efficiency,
often as much as 20 to 30 percent. Gas flow distribution problems can
be corrected by proper design, for example by adding straighteners,
splitters, vanes, and diffusion plates to the duct work before the ESP.
Scale models of the ESP and duct work are generally needed to study flow
distribution problems and possible solutions.
4.1.4 Fabric Filtration8*9
4.1.4.1 Basic Description.8 A fabric filter unit is illustrated in
Figure 4-5. As the inlet gas passes through the fabric filters, dust particles
in the inlet gas are retained on the fabric filters themselves by settling,
impaction, interception, and diffusion. The bags are then cleaned in one of
three ways. In shaker cleaning, the bags are oscillated by a small electric
motor. The oscillation shakes most of the collected dust into a hopper.
In reverse flow cleaning, backwash air is introduced to the bags to collapse
them and fracture the dust cake. Both shaker cleaning and reverse flow
cleaning require a sectionalized baghouse to permit cleaning of one section
while other sections are functioning normally. The third cleaning method,
reverse pulse cleaning, does not require sectionalizing. A short pulse of
compressed air is introduced through Venturis and directed from top to
bottom of the bag. The primary pulse of air aspirates secondary air as
it passes through the Venturis. The resulting air mass expands the bag
and fractures the cake. This method of cleaning can be effected simultan-
eously with the bag filter operation, avoiding the need for sectionalized
baghouses.
4.1.4.2 Factors Affecting Performance. The most important para-
meters in baghouse design and performance are:
4-10
-------
Dished Reverse Air Damper
Walkway Extends to "Gallery"
Where Damper Seats can be Inspected
Outlet Poppet Dampen
Dirty Gas Inlet
Figure 4-5. Example of a fabric filter.
9
4-11
-------
filter medium,
air to cloth ratio (superficial velocity),
cleaning method and cycle,
operational pressure drop,
baghouse configuration,
gas temperature and moisture content, and
particulate properties.
The removal efficiency of fabric filters is reduced by poorly-
maintained bags and caking. Worn and torn bags are evidenced by visible
emissions; a regular inspection program can help to spot stress and
wear. Caking can occur with hygroscopic materials when the temperature
of the gas drops too low. Since caking can permanently ruin bags, a
fabric filter by-pass or inlet gas heater may be needed to avoid caking
when gas temperatures drop. Higher gas temperatures can be achieved by
insulating bag filters and upstream ducting and control devices.
4.2 APPLICATION OF CONTROL TECHNIQUES TO FACILITIES IN THE
SODIUM CARBONATE INDUSTRY
Applicability of the control techniques discussed in Section 4.1 to
facilities in the sodium carbonate industry is discussed in this section.
The control techniques currently being used for the different facilities
are noted. Typical design and operating parameters and performance data
are presented. Factors affecting the applicability of other control
devices are also discussed.
4.2.1 Calciners and Bleachers
The only control devices currently being used to control emissions
from calciners and bleachers in the sodium carbonate industry are cyclones
in series with electrostatic precipitators and cyclones in series with
venturi scrubbers. All but two of the fifteen calciners in use in mono-
hydrate process plants are controlled by cyclones in series with electro-
static precipitators. The other two calciners are controlled by cyclones
in series with venturi scrubbers. Bleachersjn^ also most common!y
controlled by cyclones_ in series with^electrostatic jpreci pita tors.
Resistivity of calciner dust has been reported as 1 X 10 ohm-cm at
230°C (450°F).10 This is within the range of resistivities that have
4-12
-------
been shown to be most suitable for electrostatic precipitation (as
discussed in Section 4.1.3).
Other characteristics of sodium carbonate, such as its hygroscopic
nature, lead to problems in ESP operation, but these can be overcome
with proper design. Sodium carbonate dust is hygroscopic and sticky,
and tends to cling to electrodes. It can also clog the openings of
conventional pyramid dust hoppers, making dust removal difficult. When
the dust is not removed, it can back up into the ESP and short out
11 12
electrodes. * One vendor that has designed ESP's for sodium carbon-
ate calciners recommends the use of a properly maintained drag bottom
ESP rather than conventional pyramid hoppers for dust removal to min-
imize these dust removal problems. The dust removal system in a drag
bottom ESP consists of a square panel under the ESP, equipped with a
drag conveyor to carry away the collected dust. The conveyor must be
kept clear and moving to prevent dust from backing up into the electrodes.
However, there are no narrow openings as in pyramid hoppers to become
clogged. Problems can also result from moisture in the gas getting into
the support insulation, where it forms a film which can cause cracks. A
properly designed purge system can prevent such a film build up.
ESP's are generally designed in sections, with separate electric
fields controlled by separate transformer-rectifiers so that power input
to one section is not limited by poor performance in another. ESP's on
calciners and bleachers in sodium carbonate plants typically have three
or four separate fields. There is also a trend to design the ESP to
meet the guaranteed emission level with one section out of service.
Because of problems such as those noted above, it is not uncommon for ESP's
in sodium carbonate plants to be operated with one section out of service.
Design parameters and performance data supplied by industry for ESP's used
to control emissions from calciners and bleachers in the sodium carbonate
industry are presented in Table 4-1. Cyclones are used in front of the ESP's
Venturi scrubbers currently used to control emissions from calciners
achieve lower removal efficiencies than ESP's. Higher removal effi-
ciencies could be achieved with higher scrubber pressure drops. Based
on the removal efficiency achieved in EPA source tests of gas-fired
calciners with a scrubber pressure drop of about 85 cm (33.5 in.) of
4-13
-------
TABLE 4-1. DESIGN PARAMETERS AND PERFORMANCE DATA SUPPLIED BY INDUSTRY FOR
ELECTROSTATIC PRECIPITATORS CONTROLLING EMISSIONS FROM CALCINERS AND BLEACHERS
Facility Type
Gas-fired calclner fl
Gas-fired calclner »2
Gas-fired calclner 13
Gas-fired calclner 14
Gas-fired calclner 15
Gas-fired calcines 16
Gas-fired calclner 17
Gas-fired calclner 18
Gas-fired calclner 19
Gas-fired calclner 110
Gas-fired calclner 111 .
Coal-fired calclner fl°
Coal-fired calciner lld
Coal-fired calclner 12*
Coal-fired calclner 12*
Gas-fired bleacher fl
ESP
Vendor
NA
NA
NA
NA
NA
NA
NA
Research Cottrell
Research Cottrell
Research Cottrell
Research Cottrell
Envlrotech
Envlrotech
Envlrotech
Envlrotech
Research Cottrell
to. of
Stages
NAb
NA
NA
NA
NA
3
3
4
3
3
4
4
4
4
4
3
RaHoo
* 3to
NA
NA
NA
NA
NA
50
50
NA
NA
NA
49
67
65
63
60
35
r Mate Area
Flow Rate
ft'/lOOO acfm
NA
NA
NA
NA
NA
255
255
NA
NA
NA
248
338
329
319
305
180
Design
Efficiency
NA
NA
NA
NA
NA
99.55
99.55
99.5
99.5
99.5
99.9
98.89
99.89
98.89
99.89
99.81
Mfe
NA
NA
NA
NA
NA
0.11
0.11
NA
NA
NA
0.14
0.068
0.11
0.072
0.11
0.18
NA
NA
NA
NA
NA
0.35
0.35
NA
NA
NA
0.47
0.22
0.35
0.24
0.37
0.58
Emission Level
Ky/na icco
0.08
0.13
0.06
0.07
0.11
0.065
0.033
0.07
0.065
0.07
0.025
0.032
0.031
0.014
0.072
NA
1 V/ t>WM 1 CC\I
0.16
0.25
0.12
0.14
0.21
0.13
0.065
0.14
0.17
0.14
0.05
0.062
0.062
0.028
0.12
NA
Ixh hrdcuTaTT
Concentration
0064
. UV7
Oil
» 1 o
NA
nn
0046
• ir»o
0 046
V t Vr"*W
0 11
V • 1 1
0.055
0 098
v » V^W
Oil
• 1 1
0 066
V » WV
0.043
0.015
0.019
0.0059
0.040
0.096C
gr/ascT
Ono
.03
Once
.056
UA
NA
Ono
*Uc
0 • 02
Of\AO
. U*fO
0 0?tl
OAAl
*U4 J
OAA7
. W/
O.*019
0.0065
0 . 0082
0.0026
0.018
0.042*
^Calculated using the Deutsch-Anderson Equation
^NA-Not Available
jjDesIgn value
"These are different tests of the same calclner
These are different tests of the same calclner
-------
water, it appears that a pressure drop of about 154 cm (60 in.) of water
may be required to achieve a removal efficiency comparable to that
achieved in a four stage ESP.13
No fabric filters are used to control emissions from calciners or
bleachers in sodium carbonate plants. The sticky, hygroscopic nature of
sodium carbonate could lead to problems with bag blinding or caking,
especially if the temperature is not maintained above the dew point.
Baghouses are used to control emissions from other sources in sodium
carbonate plants, such as conveyor transfer points, crushing, and product
sizing. Some problems with bag blinding have been encountered. Bag
blinding may not be a problem with calciners and bleachers because these
gas streams are at a high temperature, about 200-230°C (400-450°F) or
about 160°C (290°F) above the dewpoint. Thus, with proper provisions
for insulating the baghouse and for preventing sudden, uncontrolled
shut-downs which would result in a rapid temperature drop in the bag-
house, blinding may not be a serious problem.
4.2.3 Dryers and Predryers
Venturi scrubbers are the only control devices currently used to
control emissions from rotary steam tube dryers in the sodium carbonate
industry. Cyclones in series with venturi scrubbers are used to control
emissions from fluid bed steam tube dryers and rotary steam heated
predryers. Both venturi scrubbers and electrostatic precipitators have
been used to control emissions from rotary gas-fired dryers.
The exhaust gas from both rotary and fluid bed steam tube dryers
and predryers in the sodium carbonate industry is well suited to control
by wet scrubbing. The sodium carbonate particles to be removed are
quite soluble and hygroscopic. These characteristics enhance the
removal of sodium carbonate particulates in wet scrubbers. However,
when these characteristics are coupled with the high water content of
the dryer exit gas, they can result in operating problems for ESP's or
baghouses. The temperature of the exit gas from rotary steam tube
dryers is about 88°C (190°F), or about 7 to 17°C (10 to 30°F) above the
saturation temperature. Exit gas temperature from fluid bed dryers is
about 130°C (250°F) or about 25-50°C (50-100°F) above saturation. Exit gas
4-15
-------
temperature from steam heated predryers is about 57°C (135°F) or about
13°C (25°F) above saturation. Thus, moisture in the exit gas could
condense in an ESP or baghouse. Wet, sticky dust would then stick to the
electrodes and hoppers of the ESP or blind and cake the bags in the
baghouse.
ESP's have been used to control emissions from rotary gas-fired
dryers, but the exit gas from these dryers is at a higher temperature and
lower relative humidity than gas from steam tube dryers. Exit gas from a
gas-fired dryer is about 150°C (300°F) with a moisture content of 20-25%,
or about 90°C (160°F) above saturation temperature. As discussed in
Chapter 3, gas-fired dryers are not expected to be used in future plants.
Design and operating parameters and performance data for scrubbers
controlling particulate emissions from dryers and predryers in sodium
carbonate plants are summarized in Table 4-2. As shown, scrubber pressure
drops range from 33 cm (13 in.) water to 97 cm (38 in.) water. Higher
scrubber pressure drops are required for fluid bed steam tube dryers and
rotary gas-fired dryers than for rotary steam tube dryers to meet comp-
arable emission levels. The higher pressure drops are required because
uncontrolled emissions from fluid bed and gas-fired dryers are higher than
those for rotary steam tube dryers. A cyclone is generally used before
the scrubber for fluid bed and gas-fired dryers, so that the gas into the
scrubber has a higher proportion of small particles than the gas from a
rotary steam tube dryer.
4.3 DATA SUPPORTING PERFORMANCE
This section presents source test data demonstrating the level of
emission control that has been achieved with the control techniques dis-
cussed in Section 4.2. Data obtained from EPA source tests are presented
in Section 4.3.1. Industry data providing additional support to the
performance level demonstrated in the EPA tests are presented in Section
4.3.2.
4.3.1 EPA Source Test Data
Source tests were conducted by EPA to demonstrate the performance
of particulate control devices on facilities in sodium carbonate plants.
Results of these tests are summarized below, and are presented in more
detail in Appendix C.
4-16
-------
TABLE 4-2. DESIGN AND OPERATING PARAMETERS AND PERFORMANCE DATA SUPPLIED
BY INDUSTRY FOR SCRUBBERS USED TO CONTROL PARTICULATE EMISSIONS FROM DRYERS AND PREDRYERS
Facility Type
Rotary steam tube dryer 11
Rotary steam tube dryer 12
Rotary steam tube dryer 13
Rotary steam tube dryer 14
Rotary steam tube dryer 15
Rotary steam tube dryer 16
Rotary steam tube dryer 17
Rotary steam tube dryer IB
Rotary steam tube dryer 19
Rotary steam tube dryer flO
Rotary steam tube dryer 111
Gas-fired dryer 11
Fluid bed steam tube dryer 11
Fluid bed steam tube dryer 12
Rotary steam tube dryer 112
Rotary steam tube dryer 113
Rotary steam heated predryer 11
Rotary steam tube dryer 114
Scrubber Type
NA
NA
NA
NA
NA
NA
VentuM
Venturl
Venturl
VentuM
Venturl
Venturl
Venturl
Venturl
Venturl
Venturl
Venturl -Rod
Venturl
Vendor
NA
NA
NA
NA
NA
NA
Oucon
Ducon
Oucon
Ducon
Oucon
Ducon
FMC
Ducon
Oucon
Oucon
R1ley
Polycon
Scrubber AP
crnHjO
NA
NA
NA
NA
NA
NA
53a
53"
53a
53a
53"
69
97
66
48
48
41
33
In. H2U
NA
NA
NA
NA
NA
NA
21"
21 •
21a
21?
21 "
27.2
38&*
26
19
19
16*
13"
, L/G Ratio
l/nr
NA
NA
NA
NA
NA
NA
•3!l
•32
•3!
.3"
.3"
NA
NA
NA
NA
NA
1.5"
0.9*
gal /1 000 acf^
NA
NA
NA
NA
NA
NA,
10!
10"
10"
10*
10"
NA
NA
NA
NA
NA
11"
7"
Emission Rate
kg/tag i-eea
0.048
0.029
0.018
NA
NA
0.05
0.01
NA
NA
0.0049
NA
0.2
0.040
0.081
0.0057
0.010
NA
NA
ID/ ton reed
0.096
0.058
0.035
NA
NA
0.10
0.02
NA
NA
0.0098
NA
0.40
0.0795
0.161
0.011
0.021
NA
NA
Exit Concentration
g/dnttr
0.078
0.048
0.057
NA
NA
0.13
0.036
NA
NA
0.027
NA
0.39
0.048
0.064
0.013
0.027
0.074
NA
gr/osct
0.034
0.021
0.025
NA
NA
0.058
0.0157
NA
NA
0.0118
NA
0.17
0.021
0.028
0.0058
0.012
0.0323d
NA
?des1gn value
pressure drop recorded during different source test
-------
4.3.1.1 Cyclone/Electrostatic Predpitator on a Coal-fired Calciner.
Results of EPA source tests on a cyclone/electrostatic precipitator
controlling emissions from a coal-fired calciner are presented in Table 4-3
and Figures 4-6 and 4-7. An_average_pyerall_ control efficiency of 99.96 percent
was achieved for the cyclone/ESP combination, with resulting particulate
emissions of 0.101 kg/Mg (0.202 Ib/ton) dry feed. The average outlet parti-
culate concentration was 0.0517 g/dry Mm3 (0.0226 gr/dscf). These emissions
include emissions from the dissolver, which was vented to the calciner control
device. The three test runs show a rather wide variation in emissions.
However, since compliance is to be based on the average of three test runs,
test data such as these would be acceptable to demonstrate compliance with
the standard.
During the souree tests, the calciner was operated at greater than
90 percent capacity. During tests 2 and 3 one section of the ESP was not
in service. All sections were operating during the first test, but the
first section was experiencing very low current and voltage.
4.3.1.2 Cyclone/Electrostatic Precipitator on a Gas-fired Bleacher
Results of EPA source tests on gas-fired bleachers controlled by cyclones
and electrostatic precipitator are summarized in Table 4-4 and Figure 4-8.
An average overall control efficiency of 99.99 percent was achieved for
the cyclone/ESP combination, with resulting particulate emissions of
0.021 kg/Mg (0.041 Ib/ton) dry feed. The average outlet particulate
concentration was 0.0149 g/Nm3 (dry) (0.0065 gr/dscf).
The emission control scheme for the bleachers consisted of one ESP
simultaneously treating emissions from three bleachers. Each bleacher
was serviced by a separate cyclone. Only two of the three bleachers
were operating during the tests. The two bleachers which were operational
during testing were operated at greater than 61 percent but less than 90 per-
cent of design capacity. However, calculations indicate that emissions at
full capacity would average 0.026 kg/Mg (0.051 Ib/ton) or less.
The dry, standard gas flow rate to the emission control equipment on
the bleacher was actually about 30 to 40 percent higher than the design gas
flow rate. This was due to the admission of ambient air between the bleachers
and the emission control equipment. (This ambient air was admitted for process
4-18
-------
TABLE 4-3. CYCLONE/ELECTROSTATIC PRECIPITATOR PERFORMANCE DEMONSTRATED
IN EPA TESTS OF A COAL-FIRED CALCINER3
Test Number
Controlled Particulate Emission Rate
kg/Mg dry feed
Ib/ton dry feed
Controlled Particulate Concentration
g/Nm3 (dry)
gr/dscf
Overall Control Efficiency %
1
0.154
0.307
0.0779
O.;0340
99.93
2
0.121
0.241
0.061s
0.0269
_b
3
0.0284
0.0568
0.0157
0.00684
99.99
Average
0.101
0.202
0.0517
0.0226
99.96
Reference 15
Inlet particulate loading was not determined.
4-19
-------
KEY:
o.ie
0.1
0.14
0.13
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a>
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>»o.n
•a
JPO.10
t.0. 09
Particulal
o o
• •
0 0
-C* en
0.03
0.02
0.01
3 Methods - Current EPA Test
O Methods - Industry Test
3 t— < Average
- —
— ^
O
i — i
• •
- «
O *""*
•• ••
o
— •
3 ^ V 0
O O
8*0*
0
1 1 1 1 1
0.32
0.30
0.28
0.26
0.24"S
01
0.22 £
0.20 o
0.18^
0)
0.16 S
o
0.14 To
0.12 ^
Q)
0.10-5
U
0.08 £
CL
0.06
0.04
0.02
A-l
A-2
A-3 A-4
A-5
Figure 4-6. Controlled particulate emission rates from coal-
fired calciners with cyclone/electrostatic
precipitator.
4-20
-------
0.08
0.07
0.06
SO. 05
4J
£0.04
o
o
50.03
£0.02
0.01
3 Method 5 - Current EPA Test
O Method 5 - Industry Test
•—i Average
O
0.03^
ri-
_j.
o
o
o
3
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CD
I
o>
0.02?
(O
Q.
(/I
•TO
O
o
o.oi
8
O
A-l A-2 A-3 A-4
Figure 4-7 Controlled particulate concentrations from coal-fired
calciners with cyclone/electrostatic precipitator
4-21
-------
TABLE 4-4. CYCLONE/ELECTROSTATIC PRECIPITATOR PERFORMANCE
DEMONSTRATED IN EPA TESTS OF GAS-FIRED BLEACHERS4
Test Number
Controlled Participate Emission Rate
kg/Mg dry feed
Ib/ton dry feed
Controlled Parti cul ate Concentration
g/NnrCdry)
gr/dscf
Overall Control Efficiency %
1
0.031
0.061
0.0234
0.0102
b
2
0.019
0.038
0.0124
O.U054
99.99
3
0.012
0.024
0.0089
0.0039
99.99
Average
0.021
0.041
0.0149
0.0065
99.99
a. Reference 16
b. Inlet participate loading was not determined.
4-22
-------
•o
0>
O>
i.
^"
€
«r
*^^
OC
§ 0.05
"SI
42 0.04
£ 0.03
J 0:02
i-
£ 0.01
» —
~
-
-
3
^
3
i
5
o
c
0»
rt-
to
m
IA
o.iol
33
D.03|
0.06^
D.043
o.
0.02^,
o.
Figure 4-8 Controlled participate emission rates from
gas-fired bleachers with cyclone/electrostatic precipitator
4-23
-------
control reasons.) The actual gas flow rate was about two to four percent
less than the design rate.
4.3.1.3 Venturi Scrubber on a Rotary Steam Tube Dryer. Results of
EPA source tests on a venturi scrubber controlling emissions from a
rotary steam tube dryer are presented in Table 4-5 and in Figures 4-9
and 4-10, The average control efficiency was 99.88 percent, with
resulting controlled emissions of 0.0356 kg/Mg (0.0711 Ib/ton) dry
3
product. The average outlet particulate concentration was 0.0867 g/dNm
(0.0379 gr/dscf). During these tests, the dryer was operated at greater
than 90 percent capacity.
4.3.1.4 Cyclone/Venturi Scrubber on a Fluid Bed Steam Tube Dryer.
Results of EPA source tests on a cyclone/venturi scrubber controlling
emissions from a fluid bed steam tube dryer are presented in Table 4-6
and Figures 4-9 and 4-10. The average overall control efficiency achieved
was 99.92 percent, resulting in average outlet emissions of 0.0379 kg/Mg
(0.0793 Ib/ton) dry product and an average outlet particulate concentration
of 0.0556 g/dNm3 (0.0243 gr/dscf). 18
As shown in Table 4-6, the outlet emissions for the first test are
over twice as high as those for the other two tests. The inlet parti-
culate rate for this test was also over twice that for the other two
tests. The overall control efficiency, however, remained relatively
constant throughout these fluctuations in the inlet particulate rate.
The reason for this fluctuation Is unknown, but may have been due to a
higher dryer draft pressure that was observed early in the first test.
During these source tests, the dryer was operated at greater than
85 but less than 90 percent of normal operating capacity. Average
4-24
-------
TABLE 4-5. VENTURI SCRUBBER PERFORMANCE DEMONSTRATED IN
EPA TESTS OF A ROTARY STEAM TUBE DRYER*
Test Number
Controlled Parti cul ate Emission Rate
kg/Mg dry product
Ib/ton dry product
Controlled Parti cul ate Concentration
g/Nm3 (dry)
gr/dscf
Overall Control Efficiency, %
Scrubber Pressure Drop
cm of water
in. of water
1
0.0326
0.0651
0.0840
0.0367
99.87
62.2
24.5
2
0.0480
0.0960
0.0973
0.0425
99.86
63.2
24.9
3
0.0262
0.0523
0.0788
0.0344
99.90
64.8
25.5
Average
0.0356
0.0711
0.0867
0.0379
99.88
63.4
25.0
Reference 15.
5Across throat.
4-25
-------
u
3
T3
E
Q.
•o
0)
01
-------
0.11
O.K
0.09
O.Ot-
0.07-
-o
ro"
i 0.0$-
cn
£ 0.0!
•M
o
o
=3
a*
o'
0.02^
o
-h
0.01
B C
Figure 4-10 Controlled particulate concentration from rotary steam
tube dryer, fluid bed steam tube dryer, and rotary steam heated
predryers with venturi scrubbers.
4-27
-------
TABLE 4.6. CYCLONE/VENTURI SCRUBBER PERFORMANCE DEMONSTRATED
IN EPA TESTS OF A FLUID BED STEAM TUBE DRYER3
Test Number
Controlled Parti cul ate Emission Rate
kg/Mg dry product
lb/ ton dry product
Parti cul ate Concentration
g/Nm3 (dry)
gr/dscf
Overall Control Efficiency, %
Scrubber Pressure Drop
cm water
inches water
1
0.081
0.162
0.113
0.0494
99.88
98.6
38.8
2
0.0271
0.0542
0.0390
0.0170
99.91
95.8
37<7
3
0.0108
0.0217
0.0150
0.00655
99.96
93.5
36.8
Average
0.0397
0.0793
0.0556
0.024c,
99.92
96.0
37.8
aReference^8
4-28
-------
scrubber pressure drop during the tests was about 96 cm (38 inches) of
water.
4.3.1.5 Cyclone/Venturi Scrubber on a Rotary Steam Heated Predryer.
Results of EPA source tests on rotary steam heated predryers controlled
by cyclones and a venturi scrubber are summarized in Table 4-7 and
Figues 4-9 and 4-10. The average overall control efficiency was 98.3
percent with resulting controlled emissions of 0.026 kg/Mg (0.052
Ib/ton) dry product. The average outlet particulate concentration was
0.0123 g/Nm3(dry) (0.0054 gr/dscf).16
The emissions control system for the predryers consisted of a
cyclone for each predryer, and one venturi rod scrubber for every two
predryers. During the tests, the two predryers were operated at greater
than 60 percent but less than 85 percent of their design capacity. However,
calculations indicate that emissions at full capacity would average
0.04 kg/Mg (.08 Ib/ton) or less. The cyclone/venturi scrubber system was
operated at a pressure drop of 46 cm (18") of water (about 43 cm (17") of
water for the venturi alone). Some ambient air was admitted at the inlet
to the venturi rod scrubber for process control reasons.
4.3.1.6 Cyclone/Venturi Scrubber on a Gas-fired Calciner. Results
of EPA source tests on a cyclone/venturi scrubber controlling emissions
from a gas-fired calciner are presented in Table 4-8. The emission
reduction achieved is less than that achieved by a cyclone/ESP on a
coal-fired calciner. At a pressure drop of 84.8 cm (33 in.) of HgO the
cyclone/ venturi scrubber control system achieved an emission rate of
0.182 kg/Mg versus a 0.101 kg/Mg emission rate achieved by the cyclone/
ESP system. In these tests, an average overall removal efficiency of
99.89 percent was achieved with an average scrubber pressure drop of
85 cm (33.4 in.) of water.
4.3.2 Industry Data Supporting Performance
Results of selected source tests conducted by the sodium carbonate
4-29
-------
TABLE 4-7. CYCLONE/VENTURI SCURBBER PERFORMANCE DEMONSTRATED IN EPA
TESTS OF ROTARY STEAM HEATED PREDRYERS
Test Number
Controlled Participate Emission Rate
kg/Mg dry product
Ib/ton dry product
Particulate Concentration
g/Nrn (dry)
gr/dscf
Overall Control Efficiency, %
Cyclone Pressure Drop
cm water
inches water
Venturi-Rod Scrubber Pressure Drop
cm water
inches water
1
0.025
0.049
0.0094
0.0041
98.3
^2.0
^Q.Q(
*43
vl7
2
0.023
0.046
0.0094
0.0041
98.4
<^2-.0
^0.80
*43
•U7
3
0.031
0.061
0.0181
0.0079
98.2
^2.0
'xfl.SO
^3
^17
Average
0.026
0.052
0.0123
0.0054
98.3
•v-2.0
M).80
-------
TABLE 4.8. CYCLONE/VENTURI SCRUBBER PERFORMANCE DEMONSTRATED
IN EPA TESTS OF A GAS-FIRED CALCINER3
Test Number
Controlled Participate Emission Rate
kg/Mg Feed
Ib/ton Feed
Controlled Parti cul ate Concentration
g/Nm3 (dry)
gr/dscf
Overall Control Efficiency, %
Scrubber Pressure Drop
cm of water
in. of water
1
0.149
0.299
0.214
0.0935
99.87
85.6
33.7
2
0.216
0.432
0.279
0.122
99.89
85.1
33.5
3
0.182
0.363
0.26G
0.117
99.90
83.8
33.0
Average
0.182
0.365
0.254
0.111
99.87
84.8
33.4
Reference 17
4-31
-------
industry are presented in this section. These tests were conducted to
demonstrate compliance with state emission regulations. Few details
were available on process operation or control equipment operating para-
meters during the tests. However, four tests conducted on coal-fired
calciners using EPA Method 5 were judged by EPA's Emission Measurements
Branch to be acceptable. Results of these tests are shown as points A-2
through A-5 on Figures 4-6 and 4-7 and are presented in Section 4.3.2.1.
4.3.2.1 Cyclone/Electrostatic Precipitator on a Coal-fired Calciner.
Emission levels reported by industry for a cyclone/electrostatic precipi-
tator controlling emissions from a coal-fired calciner are presented in
Table 4-9. These reported emission levels are lower than those demonstrated
in the EPA source tests (approximately 0.03 kg/Mg versus approximately
0.10 kg/Mg for the EPA tests). During tests I and II the calciners were
operating at a capacity comparable to that during the EPA tests, and during
tests III and IV they were operating at a lower capacity. During test I and
III one field of the ESP was out of service. During test II all fields
were in service, but the first two fields were operating with low currents.
During test IV all fields were operating normally.
4-32
-------
TABLE 4-9. EMISSION LEVELS REPORTED BY INDUSTRY FOR CYCLONE/
ELECTROSTATIC PRECIPITATORS ON COAL-FIRED CALCINERS
Run Number
I.
II.
Ill
IV.
Controlled Particulate Emission Rate
kg/Mg Feed
Ib/ton feed
Controlled Particulate Concentration
g/NnT(dry)
gr/dscf
Controlled Particulate Emission Rate
kg/Mg Feed
Ib/ton Feed
Controlled Particulate Concentration
g/Nn (dry)
gr/dscf
.Controlled Particulate Emission Rate
kg/Mg feed
Ib/ton feed
Controlled Particulate Concentration
g/NnT (dry)
gr/dscf
Controlled Particuiate Emission Rate
kg/Mg feed
Ib/ton feed
Controlled Particulate Concentration
g/Nm3 (dry)
gr/dscf
1 .
0.0426
0.0852
0.0261
0.0114
0.127
0.253
0.0705
0.0308
0.070
0.140
0.0334
0.0146
0.0134
0.0268
0.0062
0.0027
2
0.0200
0.0400
0.0117
0.00511
0.0575
0.115
0.0323
0.0141
0.0134
0.0268
0.0069
0.0030
0.0220
0.0441
0.0092
0.0040
3 .
0.0303
0.0606
0.0186
0.00812
0.0319
0.0638
0.0181
0.00791
0.0091
0.0182
0.0043
0.0019
0.0061
0.0123
0.0027
0.0012
Average
0.0310:1
0.0619
0.0188
0.00821
0.072
0.144
0.0403
0.0176
0.0308
0.0617
0.0149
0.0065
0.0138
0.0277
0.0059
0.0026
Reference 19, 20. EPA Method 5 was used in all tests.
4-33
-------
4.4 REFERENCES FOR CHAPTER 4
1. Theodore, L. and A. J. Buonicore. Industrial Air Pollution Control
Equipment for Particulates. Cleveland, Ohio, CRC Press, 1976.
pp. 91-137.
2. Reference 1, pp. 191-250.
3. Western Precipitation Division, Joy Industrial Equipment Company.
Western Precipitation Gas Scrubber, S-100. Los Angeles, California,
1978.
4. Reference 1, pp. 139-190.
5. Heinrich, R.F. and J.R. Anderson. Electro-Precipitation. In:
Chemical Engineering Practice, Vol. 3, H. W. Cremer (ed.).
New York, Academic Press, 1975. pp. 484-534.
6. Western Precipitation Division, Joy Industrial Equipment Company.
Western Precipitation Electrostatic Precipitators, P-150. Los
Angeles, California.
7. Oglesby, Sabert and Grady B. Nichols. A Manual of Electrostatic
Precipitation Technology. Prepared for the National Air Pollution
Control Administration by Southern Research Institute, August 1970.
8. Reference 1, pp. 251-302.
9. Demi try, Philip, Surinder P. Gambhir, and Terrence J. Heil. Matching
Gas Clean-up Equipment to Coal Firing Systems. Presented at Industrial
Fuel Conference, Purdue University, October 4, 1978.
10. Telecon. Sipes, T.G., Radian with W. F. Stocker, Allied Chemical
Corporation. March 20, 21, 26, 1979. Operation of and emissions
from Allied Chemical's Sodium Carbonate Plant in Green River,
Wyoming.
11. Telecon. Sipes, T.G., Radian with Peter Gunnell, Buell-Envirotech,
July 12 and 18, 1979. Cost estimates for electrostatic precip-
i tators.
12. Telecon. Sipes, T.G., Radian with James Scroggins, Texasgulf, Inc.,
August 9, 1979. Dust removal system used for calciner ESP's.
13. Memo from T.G. Sipes, Radian, to Docket. October 1979. Extrapolation
of pressure drop required for Venturi Scrubber on gas-fired calciner
to achieve higher removal efficiency.
4-34
-------
14. Blythe, G.M., J.W. Sawyer, and K.N. Trede. Screening Study to
Determine Need for Standards of Performance for the Sodium Carbonate
Industry. Radian Corp. Prepared for the Environmental Protection
Agency, October 13, 1978.
15. Environmental Protection Agency, Emission Measurement Branch. Emission
Test Program: Sodium Carbonate Manufacturing Plant Conducted at Texas-
gulf, Inc., August 1, 1979, EMB Report 79-SOD-l.
16. Environmental Protection Agency, Emission Measurement Branch,
Particulate Emissions from the Kerr-McGee Corporation Sodium Carbonate
Plant, Trona, California, March 14, 1980, EMB Report 79-SOD-3.
17. Memo from T.S. Hurley, Radian, to Docket. June 1980. Extrapolation
of bleacher and predryer test data from direct carbonation plant to
full capacity.
18. Environmental Protection Agency, Emission Measurement Branch. Emission
Test Program: Sodium Carbonate Manufacturing Plant Conducted at FMC
Corporation, March 11, 1980, EMB Report 79-SOD-2.
19. Wyoming Department of Environmental Quality, Division of Air Quality.
Particulate Stack Sampling Reports for Allied, FMC, Stauffer, and
texasgulf Sodium Carbonate Plants.
20. Wyoming Department of Environmental Quality, Division of Air Quality.
Particulate Stack Sampling Reports for Texasgulf Sodium Carbonate Plants,
4-35
-------
5. MODIFICATION AND RECONSTRUCTION
Section 111 of the Clean Air Act, as amended in 1970, 1974, and 1977,
requires the promulgation of standards of performance for new sources within
a stationary source category which "...may contribute significantly to air
pollution..." Affected facilities are those facilities for which applicable
standards of performance have been promulgated and whose construction or
modification began after proposal of the applicable standards.
When modified or reconstructed, "existing facilities" may become subject
to standards of performance. As defined in 40 CFR 60.2, an "existing
facility" is a facility for which a standard of performance has been promulgated
and whose construction or modification began before proposal of that standard.
On December 16, 1975, the Environmental Protection Agency promulgated amendments
to the general provisions to clarify modification, and an added provision to
define reconstruction. Section 5.1 summarizes those provisions of 40 CFR 60
defining the conditions under which existing facilities could become subject
to standards of performance. Section 5.2 discusses the applicability of these
provisions to facilities in sodium carbonate plants.
5.1 SUMMARY OF 40 CFR 60 PROVISIONS FOR MODIFICATIONS AND RECONSTRUCTIONS
5.1.1 Modification
Section 40 CFR 60.14 defines modification as follows:
"Except as provided under paragraphs (d), (e) and (f)
of this section, any physical or operational changes
to an existing facility which result in an increase
in emission rate to the atmosphere of any pollutant
5-1
-------
to which a standard applies shall be a modification.
Upon modification, an existing facility shall become
an affected facility for each pollutant to which a
standard applies and for which there is an increase in
the emission rate."
Paragraph (e) specifies certain physical or operational changes that
are not considered as modifications irrespective of any changes in the
emission rate. These changes include:
1) routine maintenance, repair, and replacement,
2) an increase in production rate accomplished without a
capital expenditure (as defined in Section 60.2(bb)),
3) an increase in hours of operation,
4) use of alternate fuels or raw materials if the existing
facility were designed to accommodate the alternate fuel
or raw material prior to the standard (Conversion to
coal required for energy considerations, as specified in
Section 113(d) (5) of the amended Clean Air Act is also
exempted.),
5) the addition or use of any system or device whose
primary function is the reduction of air pollutants,
except when an emission control system is removed or
replaced by a system considered to be less efficient,
and
6) relocation or change in ownership.
Paragraph (f) provides for superceding any conflicting provisions.
Paragraph (b) of CFR 60.14 clarifies what constitutes an increase in
emissions and the methods for determining the increase. These methods
include the use of emission factors, material balances, continuous monitoring
systems, and manual emission tests. Paragraph (c) of CFR 69.14 affirms that
the addition of an affected facility to a stationary source does not make
any other facility within the source subject to standards of performance.
5-2
-------
5.1.2 Reconstruction
Section 40 CFR 60.15 defines reconstruction as follows:
"An existing facility, upon reconstruction, becomes an
affected facility, irrespective of any change in emission
rate. 'Reconstruction1 means the replacement of components
of an existing facility to such an extent that: (1) the
fixed capital cost of the new components exceeds 50 percent
of the fixed capital cost that would be required to
construct a comparable entirely new facility, and (2)
it is technologically and economically feasible to meet the
applicable standards set forth in this part."
The purpose of this provision is to ensure that an existing facility
is not perpetuated by replacing all but minor components such as support
structures, frames, and housing rather than totally replacing the facility
in order to avoid becoming subject to applicable standards of performance.
5.2 APPLICABILITY TO FACILITIES IN SODIUM CARBONATE PLANTS
According to the definitions presented in Section 5.1, very few modi-
fications or reconstructions are likely to occur in the sodium carbonate
industry.
Possible changes that could be termed modification would be the
installation of larger fans on a dryer to allow an increase in production
rate, or modifying the combustion chamber of a calciner to allow an increased
fuel consumption rate and thus an increased production rate. Since increased
particulate emissions would result from the increased production rate, these
changes may be termed modifications. If these changes occur on a dryer
or calciner controlled by a venturi scrubber, however, the scrubber pressure
drop could be increased to provide additional particulate removal so that
the controlled particulate emission rate would not increase. In this case,
the change would not make the dryer or calciner subject to NSPS. However,
comparable simple changes to improve the efficiency of an ESF would not be
possible. These potential modifications are not expected to be common.
5-3
-------
They would occur as part of an expansion by de-bottlenecking, when increased
throughput would be possible in the remainder of the processing train so
that modifying the calciner or dryer to allow increased throughput would
increase the sodium carbonate production rate of the train.
Most other physical or operational changes that would occur to existing
facilities in the sodium carbonate industry would not be defined as modifi-
cations or reconstructions. Physical changes that are likely to be made
include relining of the calciner furnace, changes in the calciner combustion
chamber, and replacement of portions of the drive mechanism of a calciner
or dryer. These changes would be made as part of a routine repair and
maintenance program and would not result in an increased emission rate.
Thus, they would not be considered modifications. Moreover, since the cost
of these changes would not exceed fifty percent of the capital cost of a"
new facility, these changes would not be considered reconstruction.
Other potential modifications include changes in fuels or raw materials,
Use of fuel oil in a gas-fired calciner would not be a modification, since
the existing gas-fired calciners are designed to burn both fuel oil and
natural gas. Conversion of a gas- or oil-fired calciner to burn coal
would potentially be a modification. However, because the calciner could
process less ore when fired with coal than when fired with oil or gas, the
actual mass rate of emissions from the calciner might not be increased in
converting from gas to coal. In this case, the conversion to coal would
not be a modification. If the mass emission rate is increased, improvements
to the control device would be necessary to comply with state emission
standards. The incremental cost to comply with NSPS for this modified case
would be similar to the incremental cost for new facilities.
As noted in Chapter 3, there are a number of separate emission sources
in sodium carbonate plants. Replacement or modification of one or more
emission sources would not make the other sources in the processing train
subject to NSPS.
5-4
-------
6.0 MODEL PLANTS AND REGULATORY ALTERNATIVES
Model sodium carbonate plants and regulatory alternatives are
defined in this chapter. These model plants and regulatory alternatives
will be used in subsequent sections as the basis for analysis of the
environmental and economic impacts associated with controlling particu-
late emissions from sodium carbonate facilities.
Process flow schemes, process parameters, and uncontrolled emission
parameters for the model plants are described in Section 6.1. Regulatory
alternatives are presented in Section 6.2.
6.1 MODEL PLANTS
The model sodium carbonate plants considered in this study are de-
fined in Table 6-1. The rationale for defining the plants as combina-
tions of separate trains is discussed in Section 6.1.1. Process config-
urations represented in the model plants are discussed in Section 6.1.2.
Process and emission parameters for the model plants are presented in
Section 6.1.3.
6.1.1 Rationale for Modular Approach
As discussed in Sections 3.1 and 8.1, sodium carbonate plants typ-
ically consist of combinations of separate trains. Major plant expan-
sions involve the addition of new trains placed in parallel with existing
trains. Thus, the model sodium carbonate plants considered in this study
consist of essentially distinct trains, with a limited amount of shared
equipment. The small plant consists of only one train and the medium
size plant consists of two trains. The small plant case is representa-
tive of an expansion of an existing sodium carbonate plant. The medium
size plant (2 trains) is representative of either a new plant or a larger
expansion of an existing sodium carbonate plant.
6-1
-------
TABLE 6-1. MODEL SODIUM CARBONATE PLANTS
Number
1
2
3
4
5
6
Plant size
Small
Medium
Sma1!
Medium
Small
Medium
Number
of trains
1
2
1
2
1
2
Capacity,
106 Mg/yr (TPY)
0.454 (0.5)
0.907 (1.0)
0.454 (0.5)
0.907 (1.0)
0.454 (0.5)
0.907 (1.0)
Configuration
1
1
2
2
3
3
Process
Monohydrate
Monohydrate
Monohydrate
-
Monohydrate
Direct
carbonation
Direct
carbonation
Facilities in each train
Coal -fired calciner, rotary
steam- tube dryer
^ /
Coal -fired calciner, rotary
steam tube dryer
Coal -fired calciner, fluid
bed steam tube dryer
Coal -fired calciner, fluid
bed steam tube dryer
Rotary steam 'heated predryer,
gas-fired bleacher, rotary
steam tube dryer
Rotary steam heated predryer,
gas-fired bleacher, rotary
steam tube dryer
ro
-------
Each train has a capacity of 454,000 Mg/year (500,000 tons per year
(TRY)). The newest sodium carbonate plant in operation using the mono-
hydrate process and a monohydrate plant planned for construction both
have two trains of this capacity. The production capacity of a train is
limited by the size of equipment which can be shipped by rail. Coal-
fired calciners for the monohydrate process and bleachers for the direct
carbonation process for a train with capacities of 454,000 Mg/year
approach this limiting size.
With the exception of two small direct carbonation plants built
before 1970, all new natural process plants have had capacities of
454,000 Mg/yr or greater. As is noted in Section 8.1, most plant expan-
sions have also been approximately this size or larger. The smaller
expansions have been achieved by de-bottlenecking equipment in existing
trains or by adding parts of a new train at different times. The new
facilities added have generally had capacities corresponding to those in
a 454,000 Mg/yr train. Thus, a 454,000 Mg/yr train was selected to
represent expansions.
Sodium carbonate plants larger than 907,000 Mg/yr (one million TPY)
are in operation, but (except for the 1.2 million Mg/yr direct carb-
onation plant) all capacity was not added at the same time. Therefore,
no model plants were selected to represent a large sodium carbonate
plant.
6.1.2 Process Configurations
Three different configurations are considered for the model plants.
These configurations are shown in Figures 6-1 through 6-3. Configura-
tions 1 and 2 use the monohydrate process, and configuration 3 uses the
direct carbonation process.
These configurations have the following facilities, with individual
train capacities as shown:
Configuration 1: 1 rotary coal-fired calciner, 118 Mg/hr (130 TPH)
(monohydrate) 1 rotary steam tube dryer, 64 Mg/hr (70 TPH)
dry product
Configuration 2: 1 rotary coal-fired calciner, 118 Mg/hr (130 TPH)
(monohydrate) 1 fluid bed steam tube dryer, 64 Mg/hr (70 TPH)
dry product
6-3
-------
CONTROL
DEVICE
CONTROL
DEVICE
118 Mg/hr
(130 TPH)
CRUSHED
TRONA ORE
COAL
FIRED
CALCINER
(100 TPH)
IMPURE
DISSOLUTION
IMPURITY FILTRATION
Na«CO CRYSTALLIZATION
FILTRATION
83Mg/hr
(91 TPH)
Na2C03-H20
+Tree HgO
ROTARY
STEAM TUBE
DRYER
64 Mg/h^
(70 TPH)
Dry Na2C03
Figure 6-1. Model sodium carbonate plant - Configuration 1.
(monohydrate process)
-------
CONTROL
DEVICE
CONTROL
DEVICE
I
en
118 Mg/hr
(130 TPH)
CRUSHED
TRONA ORE
COAL
FIRED
CALCINER
(100 TPH)
IMPURE
Na2C03
DISSOLUTION
IMPURITY FILTRATION
Na?COq CYRSTALLIZATION
lixL FILTRATION
(91 TPH)
Na9COvH90
+ Free R20
FLUID BED
STEAM TUBE
DRYER
64Mg/M
(70 TPH)
Dry
Figure 6-2. Model sodium carbonate plant - Configuration 2.
(monohydrate process)
-------
I
cr>
59Mg/hr
(65 TPH)
NaHC03
(PRECIPITATED
FROM CARBONATED
BRINE)
•K10 Mg/hr water
+ SODIUM
NITRATE
t .
ROTARY
STEAM HEATED
PREDRYER
^69 Mg/hr
ret NaHC03
f SODIUM
NITRATE
— 1
' t
ROTARY
STEAM HEATED
PREDRYER
TO CARBONATION
TOWER
CO,
i
CONTROL
DEVICE
t
PARTIALLY
DRIED NaHCO.
CALCINER
82 Mg/hr
(90 TPH)
IMPURE
GAS-FIRED
BLEACHER
DISSOLUTION
FILTRATION
CRYSTALLIZATION
64 Mg/hr
(70 TPH)
Dry Na2C03
ROTARY
STEAM TUBE
DRYER
83 Mg/hr
(91 TPH)
Ya2C03-F
+ Free
Figure 6-3. Model sodium carbonate plant - Configuration 3.
(direct carbonation process)
-------
Configuration 3: 2 rotary steam heated predryers, 59 Mg/hr
(direct (65 TPH) each (dry feed)
carbonation) 1 rotary gas-fired bleacher, 82 Mg/hr (90 TPH)
1 rotary steam tube dryer, 64 Mg/hr (70 TPH)
dry product
Only the monohydrate and direct carbonation processes are repre-
sented in the model plants because all future plants are expected to use
one of the processes. As discussed in Chapter 3, neither the sesquicarb-
onate process nor the Solvay process is expected to be used in future
plants.
Although most of the calciners now used in sodium carbonate plants
using the monohydrate process are fired with natural gas, only coal-fired
calciners are represented in the model plants. Because of natural gas
shortages and potential restrictions in natural gas use, new monohydrate
process sodium carbonate plants are expected to use coal-fired calciners.
The newest monohydrate plant in operation and a monohydrate plant planned
for construction both use coal-fired calciners. Moreover, coal-fired
calciners represent a more difficult case to control. Coal-fired calci-
ners exhibit additional particulate loading due to fly ash in the coal
and higher gas volumes due to higher excess air rates.
Both rotary and fluid bed steam tube dryers are represented in the
model plants. Both dryer types are now in use in sodium carbonate plants
and are expected to be the primary dryers used in future plants. The two
dryer types have different gas flow rates and particulate loadings, and
each has relative advantages in process operation which were detailed in
Chapter 3. Natural gas-fired dryers are also currently in use in sodium
carbonate plants, but their future use will be severely limited due to
the unavailability and restricted use of natural gas. Thus, natural gas-
fired dryers were excluded from the model plants.
6.1.3 Process and Emission Parameters
Raw material feed rates and compositions, product compositions,
energy requirements and emission composition for each facility in the
model sodium carbonate plants defined in Table 6-1 are presented in Table
6-2. Uncontrolled emission parameters for each facility in the model
plants are presented in Table 6-3. These model plant parameters are
6-7
-------
TABLE 6-2. PROCESS PARAMETERS FOR MODEL SODIUM CARBONATE PLANTS
Facility
Coal -fired
calciner
Rotary steam
tube dryer
Fluid bed
steam
tube
dryer
Steam heated
predryer3
Gas-fired
bleacher
Feed
rate
Mg/h
(TPH)
118
(130)
83
(91)
83
(91)
59 ea.b
(65 ea.)
82
(90)
Feed composition
^33% Na2C03-NaHC03-2H20
(sodium sesqui carbonate)
^15% insoluble impurities
^2% water
^90% Na2C03-H20
(sodium carbonate mono-
hydrate)
^10% free water
^90% Na2C03-H20
(sodium carbonate mono-
hydrate)
M0% free water
84-94% impure NaHCO-
6-16% water J
Impure Na2C03
Sodium nitrate
(bleaching agent)
Product
Impure Na2C03
Na CO
Na2C03
85-95% impure NaHCO.,
5-15% water J
Bleached Na0CO,
2 3
Fuel rate
J/h
(Btu/h)
1.9 X It)!1 -2. 0X1 oil
(1.8 X1Q8 -1.9XlOa)
as coal
M.5X1010 7
(M.3 X 107)
as steam
(M.9 X 107)
as steam
8.9 X 109-- 3.4 X 10,10
(8.5 X 10- 3.3 X10')
3.3 X 101?- 4.1 X lol°
(2.7 X 10- 3.6 X 10 )
as natural gas
Emission composition
Particulates of impure
Na2C03 and clays.
Fly ash, S09, organics
£
Particulates of Na9CO,
C O
Particulates of Na2C03
Particulates of impure
NaHC03.
Particulates of impure
Na2C03 and sodium nitrate
CO
There are two predryers per train.
3Dry basis.
-------
TABLE 6-3.
EMISSION PARAMETERS FOR UNCONTROLLED MODEL
SODIUM CARBONATE PLANTS
(metric units)
Facility
Coal fired
calciner
Rotary
steam
tube
dryer
Coal fired
calciner
Fluid bed
steam
tube
dryer
d
Predryer
Bleacher
Rotary
steam
tube
dryer
Plant
number
1(2)
K2)
3(4)
3(4)
5(6)
5(6)
5(6)
Configuration
1
1
2
2
3
3
3
Particulate
emission rate
(kg/h)
23,000
1.940
23,000
4.54
175
2.57
1,940
Particulate
concentration
(g/dNm3)b
119
52
119
59
0.82
70
52
Gas flow rate
(actual )
(m3/min)
8,700
1,600
8,700
3,120
4,420
1,170
1,370
Gas flow rate
(standard conditions)
(Nm3/min)c
4,010
1.040
4,010
1.840
3.790
668
1.040
Gas temperature
(°C)
230
88
230
120
46
204
88
Gas pressure
(Pa)
a.ogxio4
8.06X104
4
8.06xlOq
8.06x10''
J
9.44X104
9.44X104
9.44X10*
Gas moisture
content
(percent)
2C
4C
2C
30
f.
C
40
aPlant numbers In parentheses are for medium size plants. These plants have 2 trains, each of which has the emission sources and parameters
presented. Thus, to give total emission rates and gas flow rates for the medium size plants, multiply the table values by 2.
Standard conditions are 20°C and 1.013X105 Pa.
cThe reported value Is actually a controlled flow rate. Information was not available to calculate an uncontrolled flow rate.
The reported values are for both predryers In the train.
-------
TABLE 6-3.
EMISSION PARAMETERS FOR UNCONTROLLED MODEL
SODIUM CARBONATE PLANTS
(English units)
Facility
Coal fired
calciner
Rotary
steam
tube
dryer
Coal fired
calciner
Fluid bed
steam
tube
dryer
Predryer
Bleacher
Rotary
steam
tube
dryer
Plant
number
1(2)
K2)
iv-0
3(4)
5(6)
5(6)
5(6)
Configuration
1
1
2
2
3
3
3
Particulate
emission rate
(Ibs/hr)
50,600
4,280
50.600
10,000
385
5,660
4,280
Particulate
concentration
(gr/dscf)*
52
23
52
26
0.36
30
23
Gas flow rate
(actual)
307,000
56,600
307.000
110,200
156,000
41,210
48,300
Gas flow rate
(standard conditions)
(scf/min)D
142,000
36,600
142.000
64,900
134.000
23,600
36,600
Gas temperature
m
450
190
450
248
115
400
190
Gas pressure
(psla)
11.7
11.7
11.7
11.7
13.7
13.7
13.7
Gas moisture
content
(percent)
20
40
20
30
6
8
40
CT»
I—«
O
'Plant numbers In parentheses are for medium size plants. These plants have 2 trains,each of which has the emission sources and parameters
presented. Thus, to give total emission rates and gas flow rates for the medium size plantSj multiply the table values by 2.
Standard conditions are 68°F and 14.7 psla.
°The reported value Is actually a controlled flow rate. Information was not available to calculate an uncontrolled flow rate.
The reported values are for both predryers in the train.
-------
based upon the data presented in Chapter 3 and Appendix C, scaled to the
appropriate size.
Each facility in the model sodium carbonate plants is operated
approximately 7,446 hours per year (operating factor of 85%) and is
generally operated at or near full capacity. Each train requires a land
area of about 971,000 m2 (240 acres).
6.2 REGULATORY ALTERNATIVES
6.2.1 Approach
Regulatory alternatives considered for application to the model
sodium carbonate plants are summarized in Table 6-4. For each facility,
two basic options were considered:
controlling emissions to the baseline level, which would be
required under existing state regulations, and
controlling emissions to a more stringent level based
on the best level of emission reduction demonstrated in
the sodium carbonate industry.
These two options for each facility were combined into two regulatory
alternatives for each model sodium carbonate plant:
Alternative 1 - baseline control for all facilities
Alternative 2 - more stringent control for all facilities.
Other possible alternatives would be controlling some facilities to
the more stringent level and others to the baseline level. These alter-
natives were not considered.
Another possible alternative would be a combined standard for all the
facilities in a plant. This alternative was not investigated because
it would create enforcement problems in the case of plant modifications or
expansions involving only some of the facilities.
For all facilities, particulate control equipment would be required
to meet the baseline level. The more stringent control levels would be
met by applying a more efficient control device, such as a higher pres-
sure drop scrubber or an ESP with greater plate area.
6-11
-------
6.2.2 Control Systems
As discussed in Chapter 4, several different emission control
systems can be used to control emissions from each facility to meet the
regulatory alternatives presented in Section 6.2.1. The control systems
selected for analysis of environmental and economic impacts are discussed
in this section. For most facilities, the control systems used for high
efficiency applications could be the same type as those used to meet the
baseline level, but designed and operated for a higher control effic-
iency.
6.2.2.1 Calciners. Cyclones followed in series by electrostatic
precipitators are the most common and most efficient control devices cur-
rently used for controlling particulate emissions from calciners in
sodium carbonate plants. This technique can be used to meet either the
baseline level or a more stringent level corresponding to the other
regulatory options. An ESP used to meet the more stringent emission
level would have a larger plate area than an ESP used to meet the base-
1 ine level.
6.2.2.2 Dryers and Predryers. Venturi scrubbers are the only
control devices currently used to control emissions from steam tube
dryers and steam heated predryers in the sodium carbonate industry.
Cyclones are used before the scrubbers for fluid bed steam tube dryers
and steam heated predryers, but are not used with rotary steam tube
dryers. A venturi scrubber or cyclone/venturi scrubber could be used to
meet the baseline emission level or a more stringent emission level. The
scrubber would be operated at a higher pressure drop to meet the more
stringent emission level.
6.2.2.3 Bleacher. As with calciners, cyclones followed in series
by electrostatic precipitators are most commonly used for control of
emissions from bleachers. This cyclone/ESP combination could be used to
meet the baseline emission level or a more stringent emission level. A
larger plate area would be required for the ESP to meet a more stringent
emission level.
6-12
-------
TABLE 6-4. REGULATORY ALTERNATIVES FOR MODEL SODIUM CARBONATE PLANTS
Number
la
Ib
2a
2b
3a
3b
4a
4b
5a
5b
6a
6b
Configuration
1
1
1
1
2
2
2
2
3
3
3
3
Plant
size3
small
small
med.
med.
small
small
med.
med.
small
small
med.
med.
Alternative
1
2
1
2
1
2
1
2
1
2
1
2
Calciner
baseline
high eff.
ESP
baseline
high eff.
ESP
baseline
high eff.
ESP
baseline
high eff.
ESP
Dryer
baseline
high eff.
VS
baseline
high eff.
VS
baseline
high eff.
VS
baseline
high eff.
VS
basel i ne
high eff.
VS
baseline
high eff.
VS
Predryer
baseline
high eff.
VS
baseline
high eff.
VS
Bleacher
baseline
high eff
ESP
baseline
high eff
ESP
Small plant has one train; medium plant has two trains.
ESP - electrostatic precipitator
VS = venturi scrubber
6-13
-------
7. ENVIRONMENTAL IMPACTS
This chapter discusses the environmental impacts associated with the
promulgation of New Source Performance Standards (NSPS) for particulate
emissions from emission sources in the sodium carbonate industry. The
emission sources to be considered are calciners, dryers, predryers, and
bleachers. The air quality, water pollution, solid waste, and energy
impacts associated with the application of the alternative regulatory
options are identified and discussed in Sections 7.1 to 7.4 respectively.
Additional impacts and commitment of natural resources are evaluated in
Sections 7.5 and 7.6 respectively. These impacts on the environment are
also projected over a five year period after proposal of the NSPS to
determine the long range national impact. All impacts are based on the
model plant parameters presented in Chapter 6.
7.1 AIR POLLUTION IMPACT
7.1.1 Characteristics of Emissions from Affected Facilities
The largest emission source in the sodium carbonate industry is the
coal fired calciner. Emissions consist of particulates, combustion gases
(S02> NOX), and organics (due to oil shale in trona ore). The particu-
lates, consisting mainly of Na^CO?, clays, and fly ash, are emitted in
much greater quantities than any other pollutant. The other emission
sources emit primarily Na^COo particulates.
7.1.2 Summary of Regluatory Alternatives
As discussed in Chapter 6, two regulatory alternatives were con-
sidered for the emission sources: a baseline regulatory option, and a
second more stringent control option for all emission sources.
7-1
-------
The baseline emissions of particulates are as follows:
calciner - 0.08 to 0.15 kg/Mg feed
dryer - 0.074 to 0.25 kg/Mg product (monohydrate); 0.08 kg/Mg
(direct carbonation)
predryer - 0.14 kg/Mg feed
bleacher - 0.060 kg/Mg feed.
These baseline emission levels represent the exepcted controlled emission
levels prevailing in the absence of federally promulgated New Source
Performance Standards. The rationale for selection of these baseline
levels is presented in Section 3.3.
The expected ambient air quality impacts of the proposed alternatives
are compared in Section 7.1.3. Annual emissions under each regulatory
option, projected on a five year basis, will be discussed in Section 7.1.4.
7.1.3 Primary Air Quality Impacts
A dispersion analysis was performed on each alternative to determine
the impacts of emissions from the model sodium carbonate plants on
ambient air quality. This was done using the model plants described in
Chapter 6. The higher value for baseline emissions (based on the process
weight regulation) was used in the dispersion analysis.
7.1.3.1 Emission Source Characteristics. Stack parameters for each
facility for the different control alternatives are presented in Table 7-1.
These parameters are based on information from source tests, trip reports,
and emission inventories. ' ' ' '
The stack configurations of each of the plants are shown in
Figure 7-1. For each plant the process train was aligned with the prevailing
wind direction to yield maximum ambient concentration.
7-2
-------
TABLE 7-1. STACK PARAMETERS FOR MODEL SODIUM CARBONATE PLANTS
(metric units)
i
CO
Emission
source
Coal -fired
calciner
Rotary steam
tube dryer
Coal-fired
calciner
Rotary steam
tube dryer
Coal -fired
calciner
Fluid bed
steam tube
dryer
Coal -fired
calciner
Fluid bed
steam tube
dryer
Case3
number
la(2a)
la(2a)
lb(2b)
lb(2b)
3a(4a)
3a(4a)
3b(4b)
3b(4b)
Type of
control
c/ESP
VS
c/ESP
VS
c/ESP
c/VS
c/ESP
c/VS
Parti cul ate
emission
rate
(kg/hr)
17.3
15.9
11.8
2.54
17.3
15.9
11.8
2.54
concentration
(g/dNm3)C
0.090
0.43
0.061
0.068
0.090
0.21
0.061
0.033
Gas flow rate
(actual)
(m3/min)
8690
1550
8690
1550
8690
2790
8690
2790
Gas flow rate
(standard)
(Nm3/min)c
4090
1050
4020
1050
4020
1900
4020
1900
Gas
temperature
(°C)
232
71
232
71
232
66
232
66
Gas
pressure
(Pa)
8.06X104
8.06X104
8. 06X1 O4
8. 06X1 O4
8. 06X1 O4
8. 06X1 04
8. 06X1 O4
8.06X104
Gas H20
content
(vol.S)
20
41
20
41
20
32
20
32
Stack
height
(m)
40
34
40
34
40
34
40
34
Stack
diameter
(m)
2.44
1.37
2.44
1.37
2.44
1.83
2.44
1.83
Gas
velocity
(m/sec)
31.1
17.4
31.1
17.4
31.1
17.7
31.1
17.7
-------
TABLE 7-1 (continued). STACK PARAMETERS FOR MODEL SODIUM CARBONATE PLANTS
(metric units)
Emission
source
Rotary steam
tube
predryer
Gas-fired
bleacher
Rotary steam
tube dryer
Rotary steam
tube d
predryer
Gas-fired
bleacher
Rotary steam
tube drye
Case a
number
5a(6a)
5a(6a)e
5a(6a)
5b(6b)
5b(6b)
5b(6b)
ype of
ontrol
VS
c/ESP
VS
VS
c/ESP
VS
Particulate
emission
rate
(kg/hr)
16.5
4.90
5.08
4.72
1.63
2.54
Particulate
oncentration
(g/df*n3/)C
0.078
0.13
0.14
0.023
0.044
0.068
as flow rate
(actual)
(m3/min)
4530
1170
1330
4530
1170
1330
as flow rate
(standard)
(Nm3/min)
3910
668
1040
3910
668
1040
Gas
temperature
(°C)
43
204
74
43
204
74
Gas
pressure
(Pa)
9.44X104
9.44X104
9.44X104
9.44X104
9.44X104
9.44X10*
Gas H20
content
vol.X)
9
8
40
9
8
40
Stack
height
(ml
34
34
34
34
34
34
Stack
diameter
(m)
2.44
1.22
1.37
2.44
1.22
1.37
Gas
velocity
m/sec)
16.2
16.7
15.0
16.2
16.7
15.0
"Configurations for each case are shown in Figure 7-1.
Case numbers in parentheses are for the medium size plants. These plants have 2 trains, each of which has the emission sources and parameters
presented. Thus, to give total emission rates and gas flow rates for the medium size plants, multiply the table values by 2.
c « cyclone
VS • ventuH scrubber
ESP • electrostatic predpltator
Standard conditions are 20°C (68°F) and 1.013 X 105 Pa (1 atm.).
The reported values are for both predrycrs 1n the train.
-------
TABLE 7-1. STACK PARAMETERS FOR MODEL SODIUM CARBONATE PLANTS
(English units)
en
Emission
source
Coal -fired
calciner
Rotary steam
tube dryer
Coal -fired
calciner
Rotary steam
tube dryer
Coal -fired
calciner
Fluid bed
steam tube
dryer
Coal -fired
calciner
Fluid bed
steam tube
dryer
Rotary Steam
tube d
prcdryer
Ras-f1red
bleacher
Case3
number
la(2a)
la(2a)
lb(2b)
lb(2b)
3a(4a)
3a(4a)
Type of
Control
c/ESP
VS
c/ESP
VS
c/ESP
c/VS
3b(4b)
3b(4b)
5a(6a)
5a(6a)e
c/ESP
c/VS
VS
c/ESP
Particulate
emission
rate
(Ib/hr)
38.2
35.0
26.0
5.6
38.2
35.0
26.0
5.6
36.3
10.8
Particulate
concentration
(gr/dscf)c
0.039
0.19
0.027
0.030
0.039
0.090
0.027
0.014
0.034
0.058
Gas flow rate
(actual)
(ft-Vmln)
307,000
54,600
307,000
54,600
307 ,000
98,400
307,000
98.400
160,000
41,210
Gas flow rate
(standard]
(ft3/min)c
142,000
37,000
142,000
37,000
142,000
67,200
142,000
67,200
130,000
23.600
Gas
temperature
(°F)
450
160
450
160
450
150
450
150
110
400
Gas
pressure
(psia)
11.7
11.7
11.7
11.7
11.7
11.7
11.7
11.7
13.7
13.7
Gas H20
content
(vol.S)
20
41
20
41
20
32
20
32
9
8
Stack
height
(ft)
130
110
130
110
130
110
130
110
110
110
Stack
diameter
(ft)
8.0
4.5
8.0
4.5
8.0
6.0
8.0
6.0
8.0
4.0
Gas
velocity
(ft/sec)
102
57.2
102
57.2
102
58.0
102
58.0
53.1
54.7
-------
TABLE 7-1 (continued). STACK PARAMETERS FOR MODEL SODIM CARBONATE PLANTS
(English units)
Emission
source
Rotary steam
tube dryer
Rotary steam
tube d
predryer
Gas-fired
bleacher
Rotary steam
tube dryer
Case*
number
5a(6a)
5b(6b)
5b(6b)
5b(6b)
Type of
control
VS
VS
c/ESP
VS
Partlculate
emission
rate
(Ib/hr)
11.2
10.4
3.6
5.6
Partlculate
concentration
(gr/dscf)c
0.060
0.010
0.019
0.030
Gas flow rate
(actual)
(ft3/min)
46,900
160.000
41.210
46,900
Gas flow rate
(standard)
(ft3/nrin)c
36,900
130,000
23,600
36.900
Gas
temperature
(°F)
166
110
400
166
Gas
pressure
(psia)
13.7
13.7
13.7
13.7
Gas H20
content
(vol.X)
40
9
8
40
Stack
height
(ft)
110
110
110
no
Stack
diameter
(ft)
4.5
8.0
4.0
4.5
Gas
velocity
(ft/sec)
49.1
53.1
54.7
49.1
Configurations for each case are shown in Figure 7-1. Case numbers in parentheses are for the
medium size plants. These plants have two trains, each of which has the emission sources and
parameters presented. Thus, to give total emission rates and gas flow rates for the medium size
plants, multiply the table values by 2.
c = cyclone
VS = venturi scrubber
ESP = electrostatic precipitator
Standard conditions are 20°C (68°F) and 1.013 X 105 Pa (1 atm.).
The reported values are for both predryers In the train.
-------
Model Plant
Plant 1: (cases la,lb )
Monohydrate process
Stack Configuration
1
100m
Production Rate
454,000 Mg per year
Plant 2: (cases 2a,2b)
Monohydrate process
15m
100m
100m
^i 4
907,000 Mg per year
Plant 3: (cases 3a,3b)
Monohydrate process
100m
8
454,000 Mg per year
Plant 4: (cases 4a,4b)
Monohydrate process
TV ^
Jy4^. s
15m
\€ 100m
JV. >
in
12
907,000 Mg per year
Plant 5: (cases 5a,5b)
Direct carbonation process
Plant 6: (cases 6a,6b)
Direct carbonation process
80m
80m
15m
^ 80m
100m
100m
454,000 Mg per year
907,000 Mg per year
Figure 7-1. Stack configurations for model sodium carbonate plants
KEY
coal fired calciner
dryer I _ I
predryer /\
bleacher \/
7-7
-------
7.1.3.2 Meteorological Data and Model Assumptions. The dispersion
analysis was performed to determine the maximum 24 hour and annual
average ambient air concentrations of particulates and the distance from
the stack at which these concentrations occur. Concentrations were also
predicted at downwind distances of 100, 1,000, and 10,000 meters.
The analysis used the Industrial Source Complex (ISC) Model. The
short term version of the ISC model (ISCST) was used to calculate the
hourly particulate concentrations due to each source individually and to
the combinations of the sources. These concentrations were averaged each
day to obtain the maximum 24 hour average concentrations, and over the
entire year to determine the annual average. The ISC model has been
shown to be accurate within a factor of 2.
Monohydrate plants (Case 1-4) would most likely be built in a loca-
tion similar to Sweetwater County, Wyoming. The available meteorological
data which are most representative of this area are Rock Springs, Wyoming
(surface data) and Salt Lake City, Utah (upper air data). Direct carb-
onation plants (Case 5, 6) would most likely be located near Trona,
California, where the most representative available meteorological data
are that for Las Vegas, Nevada. Meteorological data from 1964 were used
in all cases.
All plants were assumed to be located in rural areas with relatively
flat terrain. Thus, the only terrain effects included in the analysis
were those inherently present in the meteorological data.
All meteorological data were examined for invalid wind data on days
when 24 hour maximum concentrations were calculated. A total of 396
f
receptors were arranged around each plant, in radials separated by 10
degrees, to determine the maximum concentrations and their locations.
Receptors were placed at 100, 225, 360, 500, 750, 1,000, 1,250, 1,500,
2,000, 5,000, and 10,000 meters to ensure the proper calculation of the
maximum concentration.
7.1.3.3 Results and Discussions. Tables 7-2 and 7~3 summarize the
results of the dispersion modeling analysis. All of the calculated ambient
concentrations (even for baseline control levels) are well below the
7-8
-------
National Ambient Air Quality Standards (primary standards: annual
3 q
geometric mean = 75 ug/m , 24 hour concentration = 260 ug/m ; secondary
3
standards: annual geometric mean = 60 ug/m , 24 hour concentration =
o
150 ug/m )- The values presented represent concentrations in a pristine
atmosphere, and any background concentrations present at the plant sites
should be added to the calculated concentrations.
A comparison of the percent reduction in ambient conentrations
caused by switching from Alternative 1 to Alternative 2 is presented
in Table 7-4.
As indicated in Table 7-2, the greatest contributor to the ambient
concentration for the monohydrate plants in the Alternative 1 and 2 cases
is the dryer exhaust. Compared to the calciner stack concentrations, the
dryer emissions are small. However, due to the lower exit temperatures
and high moisture content of the scrubber exhaust, the dryer stack plume
has a low buoyancy. As a result, the maximum ambient concentrations due
to dryer emissions are higher than those due to calciner emissions. The
maximum concentration due to dryer emissions occurs at a point closer to
the stack than the maximum concentration due to calciner emissions. For
the direct carbonation plants, the predryer is the greatest contributor.
It is anticipated that concentrations near the calculated 24 hour
average maximum concentration will occur no more than 2 to 4% of the time
in Sweetwater County, Wyoming and less than 2% of the time in Trona,
California. This is estimated from the meteorological data used in the
dispersion analysis. The data from Sweetwater County, Wyoming contained
6-14 days with meteorological data that resulted in concentrations within
80% of the maximum calculated concentration. The meteorological data
from Trona, California contained 5 or 6 days with data of this nature.
7.1.4 Projected Growth and Particulate Emissions. Based upon
production projections by the U.S. Bureau of Mines and assuming the
closing of the single remaining Solvay process plant, the following
growth (which would be subject to NSPS) could potentially occur by 1985:
1 monohydrate plant using a rotary steam tube dryer, with
a production capacity of 0.454 million Mg/yr
7-9
-------
TABLE 7-2.
MAXIMUM 24-HOUR AMBIENT AIR PARTICULATE CONCENTRATIONS DUE TO
EMISSIONS FROM AFFECTED SODIUM CARBONATE FACILITIES
I
t—1
o
Case
No.
la
la
la
Ib
Ib
Ib
2a
2a
2a
2a
2a
2b
2b
2b
2b
2b
3a
3a
3a
Control
level
Alternative 1
(baseline)
Alternative 2
Alternative 1
(baseline)
Alternative 2
Alternative 1
(baseline)
Facilities
Coal fired calciner
Rotary steam tube
dryer
All facilities
combined
loal fired calciner
Rotary steam tube
dryer
All facilities
combined
Coal fired caliner
Rotary steam tube
dryer
Coal fired calciner
Rotary steam tube
dryer
All facilities
combined
Coal fired calciner
Rotary steam tube
dryer
Coal fired calciner
Rotary steam tube
dryer
All facilities
combined
Coal fired calciner
Fluid bed steam
tube dryer
All facilities
combined
Control
equipment
C/ESP
VS
C/ESP
VS
C/ESP
VS
C/ESP
VS
C/ESP
VS
C/ESP
VS
C/ESP
C/VS
Stack
No.
1
2
1.2
1
2
1.2
3
4
5
6
3-6
3
4
5
6
3-6
7
8
7.8
Maximum downwind .
oncentration (ug/m )
0.827
8.17
8.25
0.564
1.31
1.36
0.827
8.17
0.824
8.25
16.6
0.564
1.31
0.569
1.32
2.73
0.827
5.80
5.94
Distance to
24 hr maximum
concentration (m)
5,000
1,000
1,000
5,000
1.000
1,000
5.000
1.000
5.000
1.000
1,000
5.000
1,000
5.000
1,000
1.000
5.000
1.000
1,250
Maximum concentrations at other di stances Juo/m)
100 m
0.000
0.020
0.020
0.000
0.002
0.002
0.000
0.014
0.000
0.033
0.047
0.000
0.002
0.000
0.005
0.007
0.000
0.006
0.006
1 ,000 m
0.491
8.17
8.25
0.335
.1.31
1.36
10,000 m
0.539
1.51
1.82
0.367
0.242
0.572
i
0.491
8.17
0.488
8.25
16.6
0.335
1.31
0.333
1.3?
2.73
0.491
5.80
5.88
0.539
1.51
0.539
1.52
3.63
0.367
0.242
0.368
0.242
1.14
0.539
1.210
1-7 J
.71
-------
TABLE 7-2 (continued). MAXIMUM 24-HOUR AMBIENT AIR PARTICULATE CONCENTRATIONS DUE TO
EMISSIONS FROM AFFECTED SODIUM CARBONATE FACILITIES
Case
No.
3b
3b
3b
4a
4a
4a
4a
4a
4b
4b
4b
4b
4b
5a
5a
5a
5a
Sb
5b
5b
5b
Control
level
Alternative 2
Alternative 1
(baseline)
Alternative 2
Alternative 1
(baseline)
0 let-native 2
Facilities
Coal fired calciner
Fluid bed steam
tube dryer
All facilities
combi ned
Coal fired calciner
Fluid bed steam
tube dryer
Coal fired calciner
Fluid bed steam
tube dryer
All facilities
combined
Coal fired calciner
Fluid bed steam
tube dryer
Coal fired calciner
Fluid bed steam
tube dryer
All facilities
combined
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
All facilities
combined
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
All facilities
combined
Control
equipment
C/ESP
C/VS
C/ESP
C/VS
C/ESP
C/VS
C/ESP
C/VS
C/ESP
C/VS
VS
C/ESP
VS
VS
C/ESP
VS
Stack
No.
7
8
7,8
9
10
11
12
9-12
9
10
11
12
9-12
13
14
1Q
13-15
13
14
15
13-15
Maximum downwind .
concentration (ug/m )
0.564
0.927
1.13
0.827
5.80
0.835
5.85
12.0
0.564
0.927
0.569
0.934
2.27
7.92
1.96
2.89
10.4
2. 26
0.653
1.45
3.43
Distance to
24 hr maximum
concentration (m)
5.000
1.000
2.000
5.000
1.000
5.000
1.000
1.250
5.000
1.000
5.000
1.000
2.000
550
1.000
750
550
550
1.000
750
1,000
Maximum concentrations' at other distances (uq/m )
100 m
0.000
0.001
0.001
0.000
0.006
0.000
0.011
0.015
0.000
0.001
0.000
0.002
0.002
.394
0.002
0.529
0.529
0.113
0.001
0.265
0.265
1,000 m
0.335
0.927
0.978
0.491
5.80
0.488
5.85
11.8
0.335
0.927
0.333
0.934
1.96
7.37
1.96
2.78
10.3
2.11
0.653
1.39
3.13
10,000 m
0.367
0.193
0.554
0.539
1.21
0.539
1.21
3.41
0.367
0.193
0.368
0.193
1.11
1.08
0.292
0.385
1.73
0.308
0.097
0.193
0.590
-------
TABLE 7-2 (continued). MAXIMUM 24-HOUR AMBIENT AIR PARTICULATE CONCENTRATIONS DUE TO
EMISSIONS FROM AFFECTED SODIUM CARBONATE FACILITIES
-•4
I
»-*
ro
Case
No.
6a
6a
6a
6a
6a
6a
6a
6b
6b
6b
6b
6b
6b
6b
Control
level
Alternative 1
(baseline)
Alternative 2
Facilities
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
All facilities
combi ned
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
All facilities
combined
Control
equipment
VS
C/ESP
VS
VS
C/ESP
VS
VS
C/ESP
VS
VS
C/ESP
VS
Stack
No.
16
17
IB
19
20
21
16-21
16
17
18
19
20
21
16-21
Maximum downwind .
concentration (ug/m )
7.92
1.96
2.89
7.67
1.93
2.91
20.8
2.26
0.653
1.45
2-19
0.642
1.46
6.83
Distance to
24 hr maximum
concentration (m)
550
l.'OOO
750
550
1.000
750
550
550
1.000
750
550
1.000
750
1.000
Maximum concentrations at other distances (uQ/m3)
100 m
0.394
0.002
0.529
0.533
0.005
0.472
1.18
.113
0.001
0.265
0.152
0.002
0.236
0.498
1 ,000 m
7.37
1.96
2.78
7.36
1.93
2.79
20.7
2.11
0.653
1.39
2.10
0.642
1.40
6.83
10,000 m
1.08
0.292
0.385
1.08
0.296
0.388
3.47
0.308
0.097
0.193
0.309
0.099
0.194
1.1G
-------
TABLE 7-3.
MAXIMUM ANNUAL AMBIENT AIR PARTICULATE CONCENTRATIONS DUE TO EMISSIONS
FROM AFFECTED SODIUM CARBONATE FACILITIES
i
i-1
CO
Case
No.
la
la
la
Ib
Ib
Ib
2a
2a
2a
2a
2a
25
2b
2b
2b
2b
3a
3a
3a
Control
level
Alternative 1
(baseline)
Alternative 2
Alternative 1
(baseline)
Alternative 2
Alternative 1
(baseline)
Facilities
Coal fired calclner
Rotary steam tube
dryer
All facilities
combined
Coal fired calclner
Rotary steam tube
dryer
All facilities
combined
Coal fired calclner
Rotary steam tube
dryer
Coal fired calclner
Rotary steam tube
dryer
All facilities
combined
Coal fired calclner
Rotary steam tube
dryer
Coal fired calclner
Rotary steam tube
All facilities
combined
Coal fired calclner
Fluid bed steam
tube dryer
All facilities
combined
Control
equipment
C/ESP
VS
f
C/ESP
VS
C/ESP
VS
C/ESP
VS
C/ESP
VS
C/ESP
VS
C/ESP
C/VS
Stack
No.
1
2
1.2
1
2
1,2
3
4
5
6
3-6
3
4
5
6
3-6
7
8
7,8
Maximum downwind ,
concentration (ug/m )
0.094
1.05
1.07
0.065
0.174
0.191
0.094
1.05
0.094
1.06
2.15
0.065
0.174
0.065
0.174
0.382
0.094
0.70
0.725
Distance to
annual maximum
concentration (m)
5,000
1.000
1,000
5,000
1.000
1,250
5.000
1.000
5,000
1.000
1,000
5.000
1,000
5,000
1,000
1,250
5,000
1,250
1,250
Maximum concentrations at other distances Kuo/m^
100 m
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
1,000 m
0.018
1.06
1.07
0.014
0.174
'0.186
0.018
1.05
0.018
1.06
2.15
0.014
0.174
0.014
0.174
0.372
0.018
0.66
0.68
10,000 m
0.07
0.15
0.22
0.048
0.026
i
0.074
0.07
0.15
0.07
0.153
0.44
0.048
0.026
0.048
0.026
0.148
•
0.07
0.14
0.21
-------
TABLE 7-3. (continued). MAXIMUM ANNUAL AMBIENT AIR PARTICULATE CONCENTRATIONS DUE
TO EMISSIONS FROM AFFECTED SODIUM CARBONATE FACILITIES
Case
No.
3b
36
36
4a
4a
4a
4a
4a
46
46
46
46
46
5a
5a
5a
Sa
56
56
56
56
Control
level
Alternative 2
Alternative 1
(6ase1ine)
Alternative 2
Alternative 1
(6aseline)
Alternative 2
Facilities
Coal fired calciner
Fluid bed steam
tu6e dryer
All facilities
combined
Coal fired calciner
Fluid 6ed steam
tu6e dryer
Coal fired calciner
Fluid 6ed steam
tu6e dryer
All facilities
combined
Coal fired calciner
Fluid 6ed steam
tu6e dryer
Coal fired calciner
Fluid 6ed steam
tube dryer
All facilities
combined
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
All facilities
combined
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
All facilities
combined
Control
qui orient
C/ESP
C/VS
C/ESP
C/VS
C/ESP
C/VS
C/ESP
C/VS
C/ESP
C/VS
VS
C/ESP
VS
VS
C/ESP
VS
Stack
No.
7
8
7,8
9
10
11
12
9-12
9
10
11
12
9-12
13
14
15
13-15
13
14
15
13-15
Maximum downwind 3
oncentration (ug/m )
0.065
0.114
0.145
0.094
0.70
0.094
0.70
1.45
0.065
0.114
0.065
0.114
0.291
0.604
0.139
0.244
0.946
0-173
0.046
0.122
0.330
Distance to
annual maximum
concentration (m)
5,000
1.250
2.000
5,000
1.250
5,000
1.250
1,250
5.000
1.250
5.000
1.250
2,000
1.000
1,000
1.000
1,000
1,000
1,000
1.000
LOGO
Maximum concentrations at other distances (uq/m )
lOOm
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.003
0.000
0.011
0.011
o.ooi
0.000
0.005
0.005
1,000 m
0.014
0.108
0.122
0.018
.
0.66
0.018
0.67
1.36
0.014
0.108
0.014
0.108
0.244
0.604
0.139
• 0.244
0.946
0.173
0.046
0.122
0.330
10,000 m
0.048
0.024
0.072
0.07
0.14
0.07
0.14
0.421
0.048
0.024
0.048
0.024
0.144
0.134
0.039
jin
O.O4*
0.222
0.038
0.013
0.024
0.076
-------
TABLE 7-3. (continued). MAXIMUM ANNUAL AMBIENT AIR PARTICULATE CONCENTRATIONS DUE
TO EMISSIONS FROM AFFECTED SODIUM CARBONATE FACILITIES
•vl
I
l-»
en
Case
No.
6a
6a
6a
6a
6a
6a
6a
6b
6b
6b
6b
6b
6b
6b
Control
level
Alternative 1
(baseline)
Alternative 2
Facilities
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
All facilities
combined
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
Rotary steam tube
predryer
Gas fired bleacher
Rotary steam tube
dryer
All facilities
combined
Control
equipment
VS
C/ESP
VS
VS
C/ESP
VS
VS
C/ESP
VS
VS
C/ESP
VS
Stack
No.
16
17
18
19
20
21
16-21
16
17
18
19
20
21
16-21
Maximum downwind «
concentration (ug/m )
0.604
0.139
0.244
0.600
0.140
0.244
1.90
0.173
0.046
0.122
0.172
0.047
0.122
0.662
Distance to
annual maximum
concentration (m)
1,000
1.000
1,000
1,000
1.000
1.000
1.000
1.000
1,000
1.000
1.000
1,000
1,000
1.000
Maximum concentrations at other distances (pg/m )
100 m
0.003
0.000
0.011
0.005
0.000
0.010
0.021
0.00-1
0.000
0.005
0.001
0.000
0.005
0.010
1 ,000 m
0.604
0.139
0.244
0.60
0.140
0.244
1.90
0.173
0.046
0.122
0.172
0.047
0.122
0.662
10,000 m
0.134
0.039
0.049
0.135
0.039
0.049
0.445
0.038
0.013
0.024
0.039
0.013
0.025
0.152
-------
TABLE 7-4. COMPARISON OF MAXIMUM AMBIENT AIR CONCENTRATIONS (ug/m )
DUE TO EMISSIONS FROM MODEL SODIUM CARBONATE PLANTS
1
Model
Plant
Number
1
Facilities
Control
Equipment
i
Coal fired calciner
. Rotary steam tube
! dryer
2
3
4
C/ESP
VS
j
Coal fired calciner
Rotary steam tube
Maximum 24 hour
Concentration
Alt. 1
8.25
C/ESP i 16.6
VS
dryer •
i
Coal fired calciner ! C/ESP 5.94
)
Fluid bed dryer
Coal fired calciner
1
C/VS j
C/ESP
Fluid bed dryer C/VS
5
6
,
Rotary steam . VS
heated predryer ;
Gas fired bleacher , C/ESP
Rotary steam tube ; VS
dryer
Rotary steam VS
heated predryer
12.0
AH. 2
1-36
ireauctionj
Alt. 1
to
AH. 2
Average :
annual concentratiSn
AH. 1 AH. 2 |
83.5 1.07
1
1 1
2.73 ' 83.6
1.13
2.15
81.0 0.725
i
1
0.191
0.382
0.145
;
2.27
i
81.0
i
10.4
20.8
Gas fired bleacher C/ESP
Rotary steam tube : VS
dryer
3.43 67.0
1
6.83
67.2
i
1
,
1.45
0.946
1.90
•reduction
AH. 1
to
Alt. 2
82.1
82.2
80.0
0.291 79.9
i
0.330
0.662
I
65 .1
i
65.1
I
Includes emissions from all affected facilities
7-16
-------
1 monohydrate plant using a fluid bed steam tube dryer,
with production capacity of 0.454 million Mg/yr
1 direct carbonation plant, with a production capacity of
0.454 million Mg/yr.
There is not expected to be any replacement of existing facilities. This
growth scenario is used to provide an estimate of the potential long-range
national impacts of Alternative 2.
Table 7-5 summarizes the national particulate emissions from new and
existing sodium carbonate plants projected for the year 1985 under the regu-
latory alternatives. Under Alternative 1, particulate emissions from the
affected facilities in new sodium carbonate plants would reach 444 to
696 Mg/yr (490 to 768 TRY) by 1985. The lower value for projected emissions
is based on Wyoming's BACT requirement, and the higher value is based on the
process weight regulation, as discussed in Section 3.3. Under Alternative 2,
these emissions would be reduced to 278 Mg/yr (307 TRY). Alternative 2 thus
represents a decrease in particulate emissions ranging from 166 to 420 Mg/yr
(183 to 461 TRY).
7.1.5 Secondary Air Quality Impacts
Secondary air pollutants are pollutants generated as a result of
applying the control equipment. There are no air pollutants generated
directly by the control equipment used to achieve each control level.
There is, however, an increase in power plant emissions caused by the
additional electrical demand of the control equipment.
In the worst case (for a fluid bed dryer) the increase in particu-
lates generated at the power plant in switching from Alternative 1 to
Alternative 2 is 0.0012 kg/Mg dry product. The increase in removal of
sodium carbonate particulates caused by this action is 0.21 kg/Mg dry
product. These incremental power plant emissions of .0012 kg/Mg dry
product reduce the additional particulate removal of the control alter-
native level to 0.209 kg/Mg dry product, which is less than a one percent
impact. The increased power plant emissions would have an even smaller
impact for the other facilities.
7-17
-------
TABLE 7-5. PROJECTED NATIONAL EMISSIONS FROM
SODIUM CARBONATE PLANTS FOR 1985
00
Plant
Monohydrate (w/rotary
steam tube dryer)
Monohydrate (w/fluid bed
steam tube dryer)
Direct carbonation
Total new plant emissions0
Estimated existing plant
emissionsd
Total national emissions
Processing ^
Configuration
1
2
3
AV- ie
Mg/yr
251
251
198
700
6108
6808
TPY
275
275
218
768
6737
7505
Alt. 2
~Mg/yr
107
107
66.3
280
6108
6388
TPY
117
117
73
307
6737
7044
aBased on 7446 operating hours per year, and the process weight regulation for Alt. 1.
As defined in Chapter 6.
cNew plants are defined as plants beginning construction after 1980 and subsequently affected by
the New Source Performance Standard.
^Existing plants are defined as including plants beginning construction prior to 1980 and
subsequently unaffected by the New Source Performance Standard.
eAlt. = Alternative
-------
7.1.6 Summary of Air Quality Impacts
The primary air pollutant emissions from affected facilities in the
sodium carbonate industry are particulates, but other emissions
include organics and combustion gases. The major benefit of implementing
control alternative 2 is a reduction of particulate emissions, and thus
a potential lessening of health and ecological hazards. National emis-
sions could potentially be reduced by 420 megagrams/yr in 1985 by going
from Alternative 1 to Alternative 2. Ambient air concentrations in the
vicinity of a new plant are projected to be reduced by about 80 percent
for a monohydrate plant, and by about 65 percent for a direct carbonation
plant by implementing Alternative 2 instead of Alternative 1.
7.2 WATER POLLUTION IMPACT
The only emission control equipment which potentially results in a
wastewater stream is the venturi scrubber. The scrubber effluent is a
solution of sodium salts that will be at or near saturation and may even
contain some undissolved sodium salts.
Venturi scrubber effluents will have almost no impact on water
effluents from the plant since each scrubber discharge is similar to many
of the process streams and can be rerouted to the process with very
little impact. Scrubber effluent from product dryers is returned to the
crystallizer where valuable sodium carbonate can be recovered. The
discharge from the predryer venturi scrubber may be combined with the
exit stream of the bicarbonate dryer scrubber. This combined stream is
then used as a filter cake wash. The effluent from the cake washing is
returned to the lake salt structure to dissolve lake deposits and is
eventually recycled to the plant.
The volume and composition of scrubber effluent streams is about the
same for the different regulatory alternatives. There is no difference
in the water pollution impacts of the different alternatives.
7.3 SOLID WASTE IMPACT
There are no solid wastes generated by the application of particu-
late control equipment to the affected facilities. The particulates
removed can be reclaimed as product or used to produce additional product.
7-19
-------
For calciner and bleacher ESP's Alternative 2 would result in the removal of
44 Mg/yr (calciner) and 24 Mg/yr (bleacher) additional particulates over
Alternative 1. The amount of particulates removed in cyclones is the same
for either Alternative; the difference in particulate removal occurs in the
ESP or venturi scrubber following the cyclone. The particulates removed in
venturi scrubbers were considered in Section 7.2, Water Pollution Impact,
since they are contained in an aqueous effluent stream.
The particulates removed from the calciner exhausts are returned to
the dissolvers along with the other calcined ore. The solids removed by
the cyclone on the predryer exhaust are combined with the predryer
product and sent to the bicarbonate dryers. The particulates removed in
the bleacher cyclone are returned to the bleacher feed. The particulates
removed by the bleacher ESP can be sent to the monohydrate crystallizers
or combined with a liquid waste stream and eventually returned to the
lake salt structure.
The particulates collected by the cyclone on the fluid bed dryers
are combined directly with the dried product. The particulates removed
are very fine and may adversely affect product quality. There is,
however, no difference in impact between the two alternatives since
the quantity of particulates removed in the cyclone is the same for
both alternatives.
There are many practical methods for recycling the collected parti-
culates. In doing this the plants recover a valuable product and avoid
any potential solid waste problem which may have developed.
7.4 ENERGY IMPACT
7.4.1 Primary Energy Requirements
The emission control equipment for the sodium carbonate industry
uses electrical energy. The fans and pumps of the control systems are
the primary energy consumers. Electrostatic hrecipitators require
electricity to maintain a collecting field and rap the collection plates.
The energy requirements of the control equipment for each control
alternative and for the emission sources are presented in Table 7-6. The
incremental increase in energy consumption from Alternative 1 to Alternative
2 on a yearly basis is also shown* The largest increase is for a fluid
7-20
-------
TABLE 7-6. ENERGY REQUIREMENTS FOR MODEL FACILITIES AND
CONTROL EQUIPMENT IN THE SODIUM CARBONATE INDUSTRY
Facility
Coal fired
<~a Iciner
Rotary steam
tube dryer
Fluid bed
steam tube
dryer
Rotary steam
tube
predryer
Bleacher
a
Control3
Equipment
C/ESP
vsf
(Wyoming)
vsf
(Calif.)
C/VS
VS
C/ESP
Energy required
for facility
operation 'c
MO/ kg feed
(106Btu/ton feed)
1.8
(1-5)
0.91
/ n ~in \
(0.79)
0.91
(0.79)
0.97
(0.84)
0.29
(0.25)
0.22
(0.19)
Energy required for
control equipment
operation '
MJ/kg feed
(10s Btu/ton feed)
Alt. 1
0.0949
(0.0816)
0.0206
(0.0177)
0.0292
(0.0251)
0.0515
(0.0443)
0.031
(0.027)
0.0208
(0.0179)
Alt. 2
0.102
(0.0878)
0.0498
(0.0428)
0.0429
(0.0369)
0.127
(0.109)
0.050
(0.043)
0.0226
(0.0194)
Incremental control6
equipment energy usage for
Alt. 2 vs. Alt. 1
TJ/yr
(1010 Btu/yr)
6.2
(0.561)
17.8
(1.67)
7.85
(0.739)
46.8
(4.40)
16
(1.5)
0.92
(0.0871)
rsa
aC/ESP - cyclone/electrostatic preclpitator, VS - venturl scrubber, C/VS - cyclone/ventuH scrubber
Including thermal and electrical requirements. Steam generating efficiency, electrical gener-
ating efficiency, and line losses were taken Into account. Electrical generating efficiency
was assumed to be 34 percent with approximately a 10 percent line loss. Overall steam generating
efficiency (including line loss) was assumed to be 85 percent.
°Feed rates and compositions are reported in Table 6-2.
Based on fan and pump requirements; ESP requirements were added where necessary. Electrical
generating efficiency was assumed to be 34 percent with a line loss of about 10 percent.
eBased on 7,446 operating hours per year and production of 0.454 million Mg/yr sodium
<-arbonate.
^Discrimination between states accounts for varying climatic and elevation factors and
different baseline levels.
-------
bed dryer using a cyclone/venturi scrubber control system. For this
case the energy increase in going from Alternative 1 to Alternative 2 is
0.0757 MJ/kg product. This is equivalent to 11 percent of the net
facility consumption, but only 1,2 percent of the energy consumption
of the entire plant.
7.4.2 Projected Energy Requirements
The same growth scenario used in Section 7.1.3 to project the
national air impact for 1985 was used to project the national energy
impact. Table 7-7 summarizes the energy usage for each of the new
plants, giving the total energy requirement of the affected facilities
and of the control equipment for the alternative control levels. Also
presented is the incremental increase caused by going to Alternative 2
from Alternative 1. The total national energy increase created by
implementing control Alternative 2 as opposed to Alternative 1 is 107 TJ/yr
in d
(10.2 X 10IU Btu/yr), or 1.73 X 10 barrels of oil per year.
7.5 OTHER IMPACTS
The only other potential impact is the generation of noise by the
control equipment. The primary sources of noise from the control equip-
ment are the fans. The emission sources generate noise during combustion
(calciner, bleacher), cleaning (predryers), the intake of air (fluid bed
dryer fans, predryer fan and heat exchanger), and by the escape of steam
(rotary steam tube dryers). Compared to these existing noise sources of
the affected facilities, the noise generated by the fans associated with
the control equipment is small. There is a small increase in fan size at
the alternative control levels over the baseline, but the increase in
noise levels between these fans is only slight, if any.
7.6 OTHER CONCERNS: COMMITMENT OF NATURAL RESOURCES
A potential concern associated with increasing emission control
levels from the baseline level to the control alternative is the quan-
tity of water needed to operate a venturi scrubber. Although the scrubbing
liquor is recycled to the process, a certain percentage must be replaced
to make up for water evaporated from the venturi into the stack gas.
However, there is no difference between the makeup water demand of the
two alternatives. The quantity of water absorbed by the stack
7-22
-------
TABLE 7-7.
ENERGY REQUIREMENTS OF PROJECTED SODIUM CARBONATE PLANTS
(TJ/yr (TO10 Btu/yr))a'D
ro
oo
Plant
Monohydrate
Honohydrate
Direct
carbonatlon
New source
total
Facility
Coal-fired calciner
Rotary steam tube dryer
Total for facilities
Coal -fired calciner
Fluid bed steam
tube dryer
Total for facilities
Predryer
Bleacher
Rotary steam
tube dryer
Total for facilities
Control
equipment
C/ESP
VS
C/ESP
C/VS
VS
C/ESP
VS
Energy required
for facility
operation0
1500
(150)
560
(53)
1500
(150)
600
(56)
250
(24)
130
(13)
560
(53)
5100
500
Energy required for
control equi orient ooeratinn
Iter native 1
83
(7.9)
13
(1.2)
• 96
(9.1)
83
(7.9)
32
(3.0)
115
(10.9)
27
(2.6)
13
(1.2)
18
(1.7)
58
(5.5)
269
(25.5)
Alternative 2
90
(8.5)
31
(2.9)
121
(11.4)
90
(8.5)
78
(7.4)
168
(15.9)
44
(4.1)
14
(1.3)
26
(2.5)
84
(7.9)
373
(35.2)
Incremental increase from
Alternative to
Alternative 2
7
(0.6)
18
(1.7)
25
(2.3)
7
(0.6)
46
(4.4)
53
(5.0)
16
(1.5)
1
(0.1)
8
(0.8)
25
(2.4)
103
(9.7)
'Based on 7446 operating hours/year and production of 0.454 million Mg/yr (0.5 million TPY) sodium carbonate.
Splctl «i*rgy usage for «n tntlrt so41u» carbonate plant using the monohydnte proctss 1s 3690 TJ/yr (350 x 10 Btu/yr).
cIncludes thermal and electrical requirements. Steam generating efficiency, electrical generating efficiency,
and line losses were taken Into account. Electrical generating efficiency was assumed to be 3': percent
with approximately • 10 percent line loss. Overall stcan generating efficiency (Including line loss) was
assumed to be 85 percent.
-------
gas is based on the gas flow and other gas parameters, which
are the same at both control levels. Thus, there would be no additional
commitment of water resources due to the promulgation of Alternative 2
over Alternative 1.
7-24
-------
7.7 REFERENCES
1. Environmental Protection Agency, Emission Measurement Branch. Emission
Test Program: Sodium Carbonate Manufacturing Plant Conducted at Texasgulf,
Inc., August 1, 1979, EMB Report 79-SOD-l.
2. Environmental Protection Agency, Emission Measurement Branch. Emission
Test Program: Sodium Carbonate Manufacturing Plant Conducted at FHC
Corporation, March 11, 1980, EMB Report 79-SOD-2.
3. Trip Report. Kerr-McGee Chemical Corporation, Trona, California,
February 20, 1979. Prepared by T.G. Sipes, Radian Corporation.
4. Telecon. Sipes, T.G., Radian Corporation with W.F. Stocker,
Allied Chemical Corporation. March 20, 21, 26, 1979. Operation
of and emissions from Allied Chemical's Sodium Carbonate Plant
in Green River, Wyoming.
5. Wyoming Department of Environmental Quality, Division of Air
Quality. Particulate Stack Sampling Reports for Allied, FMC,
Stauffer, and Texasgulf Sodium Carbonate Plants.
6. Memo from David R. Pierce, Radian Corporation, to Docket.
October 8, 1979. Increased Power Plant Emissions.
7. Trip Report. Texasgulf, Inc., Granger, Wyoming. February 15,
1979. Prepared by T.G. Sipes, Radian Corporation.
7-25
-------
8. ECONOMIC IMPACTS
8.1 INDUSTRY CHARACTERIZATION
8.1.1 General Profile
As of March 1979, there were eight sodium carbonate plants in the
United States with a total capacity of approximately 8.5 million Mg/year
(9.3 million TPY). The ownership, location, startup date, capacity, and
process type for each of the eight plants are presented in Table 8-1. Employ-
ment data for the industry are also presented. There are no major byproducts
from any of the sodium carbonate processes; however, additional products are
produced concurrently in certain plants. Kerr-McGee produces sodium sulfate,
and borax and potash products, as well as sodium carbonate. FMC Corporation
produces small amounts of sodium tripolyphosphate at its sodium carbonate
plant, and Allied Chemical produces a variety of inorganic chemicals at its
Syracuse location. Production methods for soda ash are classified as either
synthetic or natural. Synthetic production has declined sharply since the mid-
19601 s, and only one synthetic plant is currently (August 1979) in operation.
The natural processes use either trona ore (an ore containing sodium ses-
quicarbonate) or a brine solution containing sodium sesquicarbonate as a raw
material. Major natural deposits of trona are located near Green River, Wyoming,
and at Searles Lake, California. All plants using a natural process are loca-
ted near one of these deposits. In Wyoming, estimated resources of halite-free
trona are 29 billion megagrams (32 billion tons). These represent about 13
billion megagrams (14 billion tons) of sodium carbonate, or at 1977 levels of
total domestic demand, about a 1900 year supply. In addition, Wyoming deposits
contain about 77 billion megagrams (85 billion tons) of less pure trona.
Mining rights to the trona ore reserves near Green River are granted by the
federal and state governments and by the Union Pacific Railroad. Sodium
carbonate resources at Searles Lake, California, are estimated at 145 million
2
megagrams (160 million tons). Mining rights to these deposits are granted
by the federal and state governments.
Three types of natural processes, the monohydrate, the sesquicarbonate,
8-1
-------
TABLE 8-1. THE DOMESTIC SODIUM CARBONATE INDUSTRY
Owner
Kerr-McGee
Allied Chem.
FMC Corp.
Stauffer Chem.
Texasgulf, Inc.
Allied Chem.
Plant Name
Trona
West End
Trona
Westvaco
Big Island
Location
Trona, CA
Trona, CA
Green River, WY
Green River, WY
Green River, WY
Green River, WY
Syracuse, NY
Startup
Datea
1978d
f
1968
1972
1947
1962
1976
1881
c Capacity
10 Mg/yr
1.2
0.14
2.0
1.13
1.13
1.54
0.91
0.8
(TRY)
(1.3)
(0.15)
(2.2)
(1.25)
(1.25)
(1.65)
(i.o)
(0.9)
Process
tvoe
Direct carbonation
Direct carbonation
Mono hydrate
Mo no hydrate
Sesqui carbonate
Mono hydrate
Monohydrate
Solvay (synthetic)
Employ-
ment
^)
/
\3600C
(
)
1800e
oo
i
ro
aStartup dates are for the original plant unless otherwise stated. See Table 8-6 for expansion
dates. Reference 3.
bCapacity data, with the exception of Kerr-McGee's Trona plant are valid through March, 1979. The
value for Kerr-McGee's Trona Plant is a planned capacity for year-end 1979.
°Value includes employment for mine and plant. 1978 value. Reference 1.
dKerr-McGee operated a small plant at this location prior to 1978. However, most of the reported
capacity was added in 1978. Reference 1.
Employment value is for the entire plant, which produces calcium chloride, chlorine, caustic soda,
sodium nitrite, ammonium chloride, and sodium sesquicarbonate in addition to soda ash. 1978
value. Reference 4.
fKerr-McGee purchased this plant from Stauffer Chemical Co. in 1974. Actual plant startup was
not determined.
-------
and the direct carbonation, are currently used. The direct carbonation
process involves the processing of a sodium sesquicarbonate containing
brine, and the monohydrate and sesquicarbonate processes involve the pro-
cessing of trona ore. Deposits in Wyoming are well suited for processing
by either the monohydrate or sesquicarbonate processes. California deposits
are better suited for processing by the direct carbonation process.
Both the direct carbonation and the monohydrate process produce a
product with a density of 960 kg/m3 (60 lbs/ft3) directly. The sesqui-
o
carbonate process produces a product with a density of 800 kg/m (50 Ibs/
3
ft ) directly, and secondary calcining is required to raise its density to
960 kg/m3 (60 lbs/ft3).
Synthetic sodium carbonate is produced in two grades, known as Light
Ash and Dense Ash. The differences between the two grades are physical
only. The density of Light Ash is between 560 and 740 kg/m (35 and 46 Ibs/
ft3), while the density for Dense Ash is between 1100 and 1200 kg/m3 (68
o
and 78 Ibs/ft ). The glass industry, the largest consumer of sodium car-
bonate, prefers the Dense Ash, while the chemical industry, another major
consumer, prefers the Light Ash.
The approximate percentages of sodium carbonate usage by the various
consumers during 1978 are presented in Table 8-2. The breakdown for 1978
is fairly typical of sodium carbonate usage during previous years. The
most significant change over the last five years is that exports are
beginning to take a larger share of production. This is further discussed
in Section 8.1.2.5.
Caustic soda is the only product which can be substituted for sodium
carbonate to any significant extent. Caustic soda can be substituted for
sodium carbonate in the chemicals, pulp and paper, cleaning agents, and
water treatment industries. These currently amount to roughly 40 percent
of the sodium carbonate markets. At present, neither caustic soda nor
sodium carbonate seems to have a distinct competitive advantage over the
other.
Imports in 1978 are estimated to have been only 7 thousand megagrams
(8 thousand tons). Exports in 1978 reached 660 thousand megagrams1 (724
thousand tons), or as indicated in Table 8-2, roughly 9 percent of domestic
production.
8-3
-------
TABLE 8-2. USES OF SODIUM CARBONATE (1978)
Use
Percent of Total
Domestic Production
Glass
Chemicals
Pulp and Paper, Cleaning Agents,
Water Treatment, and Other
Exports
^Indicates an approximate value
Reference 1.
8-4
-------
8.1.2 Trends
8.1.2.1 Historical Trends In the Method of Production. A yearly
breakdown of the domestic production of sodium carbonate for the years 1967
through 1978 is given in Table 8-3. Perhaps the most significant trend
seen in this table is the rapid decline in the synthetic (Solvay process)
production of sodium carbonate, and the correspondingly rapid increase in
the natural production. Increasing fuel costs combined with stricter water
pollution laws have made it difficult for synthetic producers to compete
with natural producers. Also, the construction of a Solvay plant generally
requires a greater capital investment.
Associated with the shift in the primary method of sodium carbonate
production has been the closing of synthetic plants and the startup and
subsequent expansions of several natural sodium carbonate plants. In 1967
there were ten synthetic sodium carbonate plants, having a combined capacity
of 5.0 million Mg/year (5.5 million TPY). As noted in Section 8.1.1, there
in only one synthetic plant presently in operation.
The first closing of those synthetic plants in existence in 1967
occurred in 1969. A yearly breakdown of the closing of plants from 1969
through 1978 is presented in Table 8-4. Eight of these plants had capacities
of either about 0.32 million Mg/year (0.34 million TPY) or 0.73 million
Mg/year (0.80 million TPY). The Dow Chemical Plant, with a capacity of
0.16 million Mg/year (0.18 million TPY), produced sodium carbonate by the
direct carbonation of caustic.
Three natural sodium carbonate plants were operating in 1967. By 1979
this number had increased to seven. Natural sodium carbonate plants
typically consist of a combination of trains, each having a capacity of
approximately 0.45 million Mg/year (0.50 million TPY). The trains can be
thought of as independent and complete processing units. Table 8-5, which
lists plant capacities by year from 1967 through 1979, indicates when start- .
ups and expansions occurred. Table 8-5 also indicates the size of the new
plants and of the expansions in capacity. Generally, from the expansion
8-5
-------
TABLE 8-3. DOMESTIC SODIUM CARBONATE PRODUCTION (1967-1978)'
Year
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Production
Svnthe"
10a mg/yr
4399
4169
4118
3986
3899
3906
3459
3181
2542 .
2127
1644
1145b
19
110s TRY)
(4849)
(4596)
(4540)
(4393)
(4298)
(4305)
(3813)
(3507)
(2802)
(2344)
(1812)
(1262)
Nature
10s mg/yr .
1566
1853
2263
2430
2600
2919
3377
3682
3927
4732
5650
6153C
(io» TPY)
(1726)
(2043)
(2495)
(2678)
(2865)
(3218)
(3722)
(4059)
(4328)
(5216)
(6228)
(6782)
Iota
"10* mg/yr
5965
6022
6381
6416
6499
6825
6836
6863
6469
6859
7294
7298b
(10* TPY)
(6575)
(6639)
(7035)
(7071)
(7163)
(7523)
(7535)
(7566)
(7130)
(7560)
(8040)
(8044)
Percent
change from
previous year
-3.4
+1.0
+6.0
+0.5
+1.3
+5.0
+0.2
+0.4
-5.8
+6.0
+6.3
•\fl.0
Percent of total
from natural production
26.3
30.8
35.5
37.9
40.0
42.8
49.4
53.6
60.7
69.0
77.5
84. 3b
"1967-1975 Reference 6; 1976-1977 Reference 1.
Estimate.
C1978 Reference 7.
-------
TABLE 8-4. SYNTHETIC SODIUM CARBONATE PLANT SHUTDOWNS (1967-1978)*
Year
1969
1970
1971
1973
1975
1976
1978
oo
i
Company
Allied Chemical
Dow Chemical
01 in Chemical
PPG Industries
01 in Chemical
Allied Chemical
Diamond Shamrock
PPG Industries
BASF-Wyandotte
Location
Vo6 Mg/year
Detroit, Michigan
Freeport, Texas
Saltsville, Virginia
Barberton, Ohio
Lake Charles, Louisiana
Baton Rouge, Louisiana
Painesville, Ohio
Corpus Christi, Texas
Wyandotte, Michigan
Capacity
0.36
0.16
0.36
0.5
0.32
0.7
0.7
0.27
0.7
TTOITPY)
(0.4)
(0.18)
(0.375)
(0.6)
(0.35)
(0.8)
(0.8)
(0.3)
(0.8)
'Reference 8.
-------
TABLE 8-5. PLANT CAPACITIES BY YEAR FOR THE NATURAL SODIUM CARBONATE INDUSTRY
(1967-1979)3
Owner
Kerr-McGee
Allied Chem.
FMC Corp.
Stauffer Chem.
Texasgulf, Inc.
PPG Industries
Stauffer Chem.
Location
Trona, CA
Trona, CA
Green River, WY
Green River, WY
Green River, WY
Granger, WY
CA
CA
10b Mq/vear
1967
0.13
1.13
0.91
c
1968
0.13
1.13
0.91
closea
0.14
1969
0.13
0.50
1.13
0.91
0.14
1970
0.13
0.50
1.13
0.91
0.14
1971
0.13
0.50
1.13
0.91
0.14
1972
0.13
0.50
0.45
1.13
1.36
0.14
1973
0.13
1.0
0.45
1.13
1.36
0.14
1974
0.13
0.14b
1.0
0.45
1.13
1.36
b
1975
0.13
0.14
1.0
0.45
1.13
1.36
1976
0.13
0.14
2.0
1.13
1.13
1.36
0.91
1977
0.13
0.14
2.0
1.13
1.13
1.54
0.91
1978
0.86
0.14
2.0
1.13
1.13
1.54
0.91
1979
1.2e
0.14
2.0
1.13
1.13
1.54
0.91
CO
I
oo
dl967-1976 Reference 9.
1977 Reference 10.
1978-1979 Reference 1.
Kerr-McGee purchased this plant from Stauffer Chemical in 1974.
cThis value was not found; however, it is believed to be small.
The author is not certain this plant was actually closed. It may have been sold to Stauffer Chemical.
eKerr-McGee plans to shut down 0.13 X 106 Mg/year of capacity during 1979 in addition to adding 0.45 X 10
Mg/year of new capacity. The listed value is the final capacity which the plant will have after these
changes. Reference 11.
-------
TABLE 8-5. PLANT CAPACITIES BY YEAR FOR THE NATURAL SODIUM CARBONATE INDUSTRY
(1967-1979)a
Owner
Kerr-McGee
Allied Chem.
FMC Corp.
Stauffer Chem.
Texasgulf, Inc.
PPG Ind.
Stauffer Chem.
Location
Trona, CA
Green River, WY
Green River, WY
Green River, WY
Granger, WY
CA
CA
10° Tons/yr.
1967
0.14
1.25
1.0
c
1968
0.14
1.25
1.0
closed
0.15
1979
0.14
0.55
•
1.25
1.0
d
0.15
1970
0.14
0.55
1.25
1.0
0.15
1971 i
0.14
0.55
1.25
1.0
0.15
1972
0.14
0.55
0.5
1.25
1.5
0.15
1973
0.14
1.1
0.5
1.25
1.5
0.15
1974
0.14
0.15b
1.1
0.5
1.25
1.5
b
1975|
0.14
0.15
1.1
0.5
1.25
1.5
1976
0.14
0.15
2.2
1.25
1.25
1.5
1.0
1977
0.14
0.15
2.2
1.25
1.25
1.7
1.0
1978
0.94
0.15
2.2
1.25
1.25
1.7
1.0
1979
1.3e
0.15
2.2
1.25
1.25
1.7
1.0
oo
i
10
1967-1976 Reference 9.
1977 Reference 10.
1978-1979 Reference 1.
bKerr-McGee purchased this plant from Stauffer Chemical in 1974.
cThis value was not found; however, it is believed to be small.
dThe author is not certain this plant was actually closed. It may have been sold to Stauffer Chemical,
_ C
eKerr-McGee plans to shut down 0.14 X 10 TPY of capacity during 1979 in addition to adding 0.50 X 10
TPY of new capacity. The listed value is the final capacity which the plant will have after these
changes. Reference 11.
-------
size, the number of trains added can be determined. For example, Allied
Chemical added one train in 1973, and Stauffer added one train in 1972.
Stauffer's expansion in 1977 was only 0.18 million Mg/year (0.2 million TRY),
which is too small to be a complete train. This expansion was a result of
equipment modification in the existing plant along with the addition of some
new equipment.
8.1.2.2 Historical Trends In The Geographical Distribution Of Plants.
The closing of synthetic plants and the opening of natural sodium carbonate
plants in Wyoming and California resulted in a relatively rapid change in
the geographical distribution of sodium carbonate production. Unlike trona
ore deposits, supplies of salt and limestone, the primary raw materials of
the Solvay process, are relatively well distributed. The nine Solvay
plants operating in 1967 were located in six states as follows: two in
Louisiana, two in Michigan, two in Ohio, one in Texas, one in New York, and
one in Virginia. While these plants were in operation they had the advantage
of being closer to the markets than the natural producers in Wyoming.
Practically all sodium carbonate from producers in Wyoming is shipped
by fail. The volume rate of production makes shipment by truck impractical.
A railroad strike or a shortage of rail cars can have serious, but probably
13
short term, detrimental effects on the sodium carbonate industry in Wyoming.
Heavy winter storms can also cause temporary transportation problems.
One benefit of the Wyoming location is the availability of large coal
supplies. Recent expansions and new plants have been designed to burn coal
as the primary fuel. Future expansions and new plants will probably be
designed to burn coal also.
8.8.2.3 Historical And Future Trends In Production. The average
annual growth rate in total sodium carbonate production between 1967 and
1977 was 2.0 percent per year. This is only slightly higher than that of
the 30 years through 1974 during which it was 1.6 percent per year.
Historically, the growth in sodium carbonate production rate has been slow
but relatively stable. Projected annual growth rates in production from
1976 through 1985 and from 1976 through 2000 are 3.0 percent and 2.6 percent
8-10
-------
respectively. These growth rates represent a slight increase in the growth
rate of annual sodium carbonate production over that of previous years.
Projected U. S. demand and production for the years 1985 and 2000 are
presented in Table 8-6. Extrapolated production, based on previous trends,
is also contained in this table. Projections were made by the U.S. Bureau
of Mines by analyzing past records and making correlations with common
economic indicators. Known factors likely to influence or distort the
projections were taken into account. Two of the more significant of these
factors are the caustic soda market and the export market. (A more thorough
explanation of how the projections were made may be obtained from Dennis
Kostick of the U.S. Bureau of Mines, Division of Nonmetallic Minerals.)
8.1.2.4 Competition With Caustic. As noted in Section 8.1.1, sodium
carbonate is subject to competition with caustic soda in what presently
amounts to roughly 40 percent of its markets. Until 1975 caustic had a
distinct advantage in these markets. In 1975, caustic prices rose enough
to seriously damage its ability to compete with sodium carbonate. The
reasons behind the 1975 price increases are presented in a 1976 publication
by the Executive Office of the President, Council on Wage and Price
Stability, entitled A Study of Chlorine, Caustic Soda Prices. Recently,
the prices of caustic have become more competitive so now neither caustic
nor sodium carbonate holds a distinct advantage.
The ability of sodium carbonate to compete with caustic is dependent
upon its relative cost of production. A significant percentage of the total
cost of production for both caustic soda and sodium carbonate is due to
energy costs; Approximately 7.3 X 10 joules (6.9 X 10 BTU) of energy are
required to produce one megagram (1.102 tons) of sodium carbonate by the
monoh.ydrate process (the most commonly used of the natural processes). The
electrolytic production of an equivalent amount of caustic, .754 megagrams
(0.831 tons) (using sodium oxide, Na90, as a common denominator), requires
10 7 9^
approximately 1.5 X 10 joules (1.4 X 10 BTU) of energy. However, this
includes the co-production of .685 megagrams (0.755 tons) of chlorine.
The market for chlorine has a strong influence on the competitiveness
of caustic soda. Generally, when the demand and production of chlorine is
8-11
-------
TABLE 8-6. PROJECTED U.S. DEMAND AND PRODUCTION OF
SODIUM CARBONATE FOR 1985 AND 2000
Year
1985
2000
o Demand ^
10J Mg/yr
7900
11,500
(10° TPY)
(8700)
(12,700)
Extrapolated
^ production3.
10J Mg/yr
8300
10,200
(10J TPY)
(9100)
(11,200)
Projected
~ productiont?
10° Mg/yr
9000
12,660
(10J TPY)
(9900)
(13,950)
Extrapolated from previous trends.
00
I
ro
on past records and common economic indicators.
Reference 15.
-------
high, the amount of available caustic is high enough that it can be priced
to compete with soda ash. The expected outlook for the future is that
caustic will continue to be a strong competitor with sodium carbonate; how-
ever, competition from caustic is not expected to have any serious
detrimental impact on future sodium carbonate demand.
8.1.2.5 Exports and Imports. Most sodium carbonate production outside
the U.S. is by the Solvay process. Known trona deposits in other countries
are relatively small, and the U.S. is the only significant producer of
natural sodium carbonate. It is conceivable that environmental issues could
lead to the closing of a number of Solvay plants in the industrialized
nations of Europe or Asia. If this occurs, these countries may increase
their imports of U.S. sodium carbonate, and this increase would have a
strong positive influence on the industry in this country. As of this
writing, there does not seem to be much of a movement to close Solvay plants
15
in Europe or Asia.
At present, U.S. sodium carbonate has difficulty competing in the West
European market with sodium carbonate from Eastern Europe. Some countries
in Western Europe feel that Eastern Europe is dumping sodium carbonate, or
selling it below production costs. It is being sold at a relatively low
price, which hurts domestic producers in Western Europe. Some type of trade
protection by the governments of West European countries may result. The
potential effects on future U.S. exports to these countries is uncertain.
Annual exports between 1967 and 1978 are presented in Table 8-7. The
growth rate in annual exports has been relatively strong over the past 10
years, and this rate has outstripped the growth rate in annual production.
Projections of exports were not found. Therefore, future exports were
estimated by taking the differences between projected production and demand
for the years 1985 and 2000, These differences are 1.09 million megagrams
(1.20 million tons) for 1985, or 12.1 percent of production, and 1.13
million megagrams (1,25 million tons) for 2000, or 8.9 percent of production
Annual exports will probably increase; however, as previously discussed, a
number of factors influence exports, and these factors are difficult to
accurately predict.
8-13
-------
TABLE 8-7. U.S. EXPORTS BETWEEN 1967 AND 1978
Year
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Exports
103 megagrams
276
261
294
305
396
435
386
512
480
585
689
657
(103 tons)
304
288
324
336
437
480
425
564
529
645
759
724
Percent of Total
Production
4.6
4.3
4.6
4.7
6.1
6.4
5.6
7.5
7.4
8.5
9.4
-------
Imports have historically been of an insignificant quantity. There is
no indication that this situation will change.
8.1.2.6 Historical And Future Trends In Prices. The prices of
synthetic sodium carbonate, f.o.b. plant, have historically been, and
presently are, somewhat higher than the f.o.b. plant prices for natural
sodium carbonate. However, most natural sodium carbonate has to be shipped
greater distances to its markets. These transportation costs for natural
sodium carbonate generally offset the f.o.b. plant price advantage of
natural sodium carbonate over synthetic sodium carbonate. Average f.o.b.
plant prices for synthetic and natural sodium carbonate for the years 1967
through 1978 are presented in Table 8-8. Synthetic sodium carbonate is
produced in two grades, Light Ash and Dense Ash. Dense Ash has always been
priced slightly higher than Light Ash. The difference during those years
that data were found, 1967 through 1972, was under one dollar per megagram.
The price figures reported in Table 8-8 for the years 1967 through 1972 were
calculated by multiplying the prices for Light Ash and Dense Ash by their
respective fraction of total synthetic production and then adding the two
products. The ratio of Light Ash to Dense Ash was approximately 2 to 3 for
the years 1967 through 1972. Price data for Dense Ash from 1973 to the
present were not found. However, since the price difference between Light
Ash and Dense Ash was found to be small, the reported figures, which are
for Light Ash only, should be sufficiently accurate for most calculations.
As indicated in Table 8-8, actual prices have increased rapidly in the
recent past. Since 1970, prices for both synthetic and natural sodium
carbonate have approximately tripled. This trend of increasing prices is
expected to continue. Allied Chemical and Texasgulf raised prices by 5.5
dollars per megagram (5 dollars per ton) of bulk natural sodium carbonate
as recently as April, 1979.15
In addition to actual prices, prices normalized to the 1978 value of
money are reported in Table 8-8. These normalized prices were calculated
from the actual prices by applying inflation index factors reported in the
•jo
"GNP Implicit Price Deflator for 1978". A graphical presentation of the
normalized prices is presented in Figure 8-1. Two basic trends in
8-15
-------
TABLE 8-8. SODIUM CARBONATE PRICES (1967-1978)
00
I
Year
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
Synthetic*
$/megagram
32.43
32.46
32.32
33.96
34.53
38.13
40.34
53.06
66.93
79.29
b
110C
$/ton
29.42
29.45
29.32
30.81
31.33
34.59
36.60
48.14
60.72
71.93
96
normalized $/megagram
62.42
59.79
56.68
56.53
54.69
57.99
57.99
69.56
80.06
90.16
b
no
normalized $/ton
56.62
54.25
51.42
51.29
49.63
52.61
52.61
63.11
72.63
81.79
96
Natural d
$/megagram
25.89
22.72
22.50
23.18
23.38
24.56
27.95
37.33
46.52
54.78
59.71
67e
$/ton
23.49
20.61
20.41
21.03
21.21
22.28
25.36
33.87
42.20
49.70
54.17
normalized S/megagram
49.83
41.85
39.46
38.59
37.03
37.35
40.18
48.94
55.65
62.29
64.13
67
normalized S/ton
45.21
37.96
35.80
35.01
33.60
33.89
36.46
44.40
50.48
56.51
58.18
61
!967-1972 values were calculated as a weighted average of the prices for Dense Ash and Light Ash.
ft. Reference ,9.
bValue was not obtained.
Wing 1978 the bulk price increased to 110/meqaqram ($96/ton) from a previous price of $94/meqaqram ($B5/ton)
dl 967-1 974 Reference 13.
1974-1976 Reference 21.
1977 Reference 10.
Wing 1978 the bulk price Increased to $67/*gagram ($61/ton) from a previous price of $61/megagram <$55/ton). Reference 20.
-------
(O
cn
to
CD
CD
CO
i-
(1) (13
Oi—
•r- i—
s_ o
Q- O
-o
OJ
N
03
O
105.OO
100.00
95.00--
90.00'
85.00"
80.00
75.00
70.004-
65.00
60.00
55.00
50.00
45.001
40.00
35.00
m /
Synthetic
67 68 69 70
71 72 73
Year (19—)
74 75 76 77 78
Figure 8-1
F.o.b. plant prices for natural and synthetic
sodium carbonate normalized to a 1978 base.
8-17
-------
normalized prices are indicated. These are the decrease in normalized
prices through 1971, and the subsequent increase in normalized prices which
became significant in 1973.
The decrease in normalized prices through 1971 can be attributed
partially to competition between caustic soda and sodium carbonate (Normal-
ized prices of caustic soda also decreased during this period), and some
competition between natural and synthetic sodium carbonate. Energy prices
were relatively stable during this period. In 1973 energy prices increased
at a rate substantially higher than the rate of inflation. As discussed in
Section 8.1.2.4, a significant portion of the total cost of production of
sodium carbonate is energy cost. The rapid increase in energy costs since
1973 is believed to be the major contributor to the increase in normalized
sodium carbonate prices.
In addition to energy, more raw materials, labor, and cooling water are
used per ton of product in the Solvay process than in any of the natural
processes. A comparison of the usage of these items in the Solvay process
and the monohydrate process is given in Table 8-9.
If normalized price trends since the early 1970's are an indication
of future trends, normalized prices will continue to increase. Figure 8-2
contains linear extrapolations over the next 5 years of natural sodium
carbonate prices normalized to the 1978 value of money. Extrapolation based
on price trends during the previous 5 years and the previous 3 years are
presented. The extrapolations are based on a least squares fit to the
average normalized price by year.
8.1.2.7 Utilization of Capacity. Yearly industry average utilization
factors for producers of sodium carbonate may be derived by taking the
ratio of production, listed in Table 8-4, to capacity, reported in Tables
8-5 and 8-6. Accurate utilization factors during those years of plant
closings, plant startups, or plant expansions cannot be obtained by this
method. Utilization factors were calculated for the years 1967, 1968, 1972,
and 1974 for the synthetic industry. No trends were seen in these yearly
utilization factors. The average value was 0.89. For the natural sodium
carbonate industry, utilization factors were calculated for 1968, 1970,
8-18
-------
TABLE 8.9. RAW MATERIAL, LABOR, COOLING WATER, AND ENERGY USAGES FOR
PRODUCTION OF SODIUM CARBONATE BY THE SYNTHETIC
AND THE MONOHYDRATE PROCESS
L
10
Raw Materials - Mg per Mg of product
(ton per ton of product)
Labor - Manyear per Mg of product
(Manyear per ton of product)
3
Cooling Water - m per minute per Mg of product
(gal. per minute per ton of
product)
Energy Requirements -
Joules per Mg of product
(BTU per ton of product)
Synthetic
8
(8)
1.1 X 10"3
(1 X 10"3)
8 X 10"2
(20)
1.58 X 1010
(13.6 X 106)
Monohydrate
2.5
(2.5)
5.5 X 10"4
(5 X 10"4)
5 X 10"3
(
-------
CO
CD
ro
CT
03
S-
OJ fO
O i—
•r~ i—
s- o
Q. O
•o
-------
1971, 1974, and 1975. No trends were seen in these yearly utilization
factors. The average was 0.92.
The utilization factors caculated above are relatively high. It
appears that the sodium carbonate industry has been producing at essentially
a maximum rate since 1967, considering that downtime from equipment and
manpower problems are included in the calculated utilization factors.
There is no indication that this will change in the foreseeable future.
8.1.2.8 Replacement of Equipment. Most of the natural sodium carbo-
nate plants are relatively young considering the expected service life of
the processing equipment. The major pieces of processing equipment can be
expected to have an indefinite service life (+30 years). Thus, replacement
of worn out or depreciated equipment is not expected to be a significant
cost over the next five years.
8.1.2.9 Future Construction Of New Plants And Additions To Existing
Capacity. Construction of new natural sodium carbonate plants and the
expansion of existing natural sodium carbonate plants will occur in the
near future. Both Stauffer and FMC Corporation have expansions of approxi-
mately 0.27 million Mg/year (0.3 million TRY) planned for completion in
15
early 1981. Tenneco plans to complete construction on a new 0.91 million
Mg/year (1.0 million TRY) plant in Wyoming by 1982.20
In addition to these additions to present capacity, construction of
three new plants with production capacities of 454,000 Mg/yr (500,000 TPY)
each could occur by 1985. This projection is based on the production
projections made by the U.S. Bureau of Mines and on the assumption that
the single remaining Solvay process plant will be shut down.
Additions to natural sodium carbonate capacity, subsequent to those
additions mentioned above, will probably occur both by the startup of new
plants and by the expansion of existing plants. New plants will probably
be constructed near the ore deposits at Green River, Wyoming or Searles
Lake, California. Other potential sites are Owens Lake, California, where
8-21
-------
there are deposits similar to those at Searles Lake, and areas in Utah and
Colorado which have large deposits of nahcolite,24 a sodium ore. However,
if historical trends continue, most future activity will be near Green River,
Wyoming. The consensus of opinions among plant engineers in this area is
that any new facilities will employ either the monohydrate or an anhydrous
25
process. The anhydrous process involves the same unit operations as the
monohydrate process, but the crystals from the crystallizers in the
anhydrous process do not contain bound water. Crystals from the crystallizers
in the monohydrate process contain bound water which must be removed in the
product dryers. Operating conditions in the crystallizer are different in
the anhydrous process to allow generation of these different crystals.
8.2 COST ANALYSIS OF REGULATORY CONTROL ALTERNATIVES
8.2.1 Introduction
An analysis of the costs of regulatory control alternatives for the
sodium carbonate industry is presented in this section. Model sodium
carbonate plants and regulatory alternatives on which the cost analysis is
based are discussed in Chapter 6 and summarized in Tables 8-10, 8-11 and
8-12.
As shown in Table 8-10, six model plants are defined. Three of the
plants have one processing train that produce 454,000 Mg/yr (500,000 TRY)
sodium carbonate and three plants have two processing trains that produce a
total of 907,000 Mg/yr (1,000,000 TRY). Each facility is assumed to operate
at full capacity 7446 hours per year (85 percent capacity factor).
The characteristics of the stack emissions before their control are
presented in Table 8-11 for the facilities in these model sodium carbonate
plants. Control options for each of the facilities in the model plants are
presented in Table 8-12. The percent reduction given in Table 8-12 is
based on the uncontrolled particulate emission rates presented in Chapter 6
(Table 6-3) and controlled particulate emission rates presented in Chapter
7. The particulate emission rate for existing plants (see baseline alterna-
tives in Table 8-12) is based on SIP requirements for the states of Wyoming
and California, as discussed in Section 3.3. Emission rates for the other
8-22
-------
TABLE 8-10. MODEL.SODIUM CARBONATE PLANTS
Number
1
2
3
4
5
6
Plant size
Small
Medium
Small
Medium
Small
Medium
Number
of trains
1
2
1
2
1
2
Capacity,
106 Mg/yr (TPY)
0.454 (0.5)
0.907 (1.0)
0.454 (0.5)
0.907 (1.0)
0.454 (0.5)
0.907 (1.0)
Configuration
1
1
2
. 2
3
3
Process
Monohydrate
Monohydrate
Monohydrate
Monohydrate
Direct
carbonation
Direct
carbonation
Facilities in each train
Coal -fired calciner, rotary
steam tube dryer
Coal -fired calciner, rotary
steam tube dryer
Coal -fired calciner, fluid
bed steam tube dryer
Coal-fired calciner, fluid
bed steam tube dryer
Rotary steam 'heated predryer,
gas-fired bleacher, rotary
steam tube dryer
Rotary steam heated predryer,
gas-fired bleacher, rotary
steam tube dryer
9°
ro
CJ
-------
TABLE 8-11. EMISSION PARAMETERS FOR UNCONTROLLED MODEL SODIUM CARBONATE PLANTS
Facility
Coal -fired
Calciner
Rotary Steam
Tube Dryer
Coal -fired
Calciner
Fluid Bed
Steam Tube Dryer
Predryer
Bleacher
Rotary Steam
Tube Dryer
Plant
Number
1 (2)
1 (2)
3 (4)
3 (4)
5 (6)
5 (6)
5 (6)
Feed rate
Mg/hr
(tph)
118
(130)
64e
(70)
118
(130)
c
64
(70)
1186
(130)
82
(90)
c
64
(70)
Gas flov
Actual
m3/min
(acfm)
8,700
(307,000)
1,600
(56,600)
8,700
(307,000)
3,120
(110,200)
4,420
(156,000)
1,170
(41,210)
1,370
(48,300)
tf rate
Standard^
Nm3/min
(scfm)
4,010
(142,000)
1,040
(36,600)
4,010
(142,000)
1,840
(64,900)
3,790
(134,000)
668
(23,600)
1,040
(36,600)
Parti cul ate
Concentration
g/dNm3
(gr/dscf)
119
(52)
52
(23)
119
(52)
59
26
0.82
(0.36)
70
(30)
52
(23)
Gas
Temp.
°C
230
(450)
88
(190)
230
(450)
120
(248)
46
(115)
204
(400)
88
(190)
Moisture
Content
Vol.
20
40
20
30
6
8
40
ro
aPlant numbers in parentheses are for medium size plants. These plants have 2 trains, each of which
has the emission sources and parameters presented. Thus, to give total emission rates and gas flow
rates for the medium size plants, multiply the table values by 2.
Standard conditions are 20°C and 1.013xl05 Pa (68°F and 14.7 psia).
cDry product.
The reported values are for both predryers in the train.
eDry basis.
-------
TABLE 8-12. CONTROL OPTIONS FOR MODEL SODIUM CARBONATE PLANTS
Case
Number
la
Ib
2a
2b
3a
3b
Plant3
Size
S
S
M
M :
S
S
Alternative
Alt. 1 -Baseline
Alt. 2
Alt. 1 -Baseline
Alt. 2
Alt. 1 -Baseline
Alt. 2
Facilities
Coal fired calciner
Rotary steam tube dryer
Coal -fired calciner
Dissolver
Rotary steam tube dryer
Coal fired calciner
Rotary steam tube dryer
Coal -fired calciner
Rotary steam tube dryer
Coal -fired calciner
Fluid bed steam tube dryer
Coal -fired calciner
Fluid bed steam tube dryer
Type of Control
C/ESP
VS
C/ESP
None
VS
C/ESP
VS
C/ESP
VS
C/ESP
C/VS
C/ESP
C/VS
% Reduction
99.92
99.18
99.95
None
99.87
99.92
99.18
99.95
99.87
99.92
99.65
99.95
99.94
ro
in
-------
TABLE 8-12. CONTROL OPTIONS FOR MODEL SODIUM CARBONATE PLANTS (continued)
Case
Number
4a
4b
5a
5b
6a
6b
Plant3
Size
M
M
S
S
M
M
Alternative
Alt. 1 -Baseline
Alt. 2
Alt. 1 -Baseline
Alt. 2
Alt. 1-Baseline
AH. 2
Facilfties
Coal fired calciner
Fluid bed steam tube dryer
Coal -fired calciner
Fluid bed steam tube dryer
Predryer
Bleacher
Rotary steam tube dryer
Predryer
Bleacher
Rotary steam tube dryer
Predryer
Bleacher
Rotary steam tube dryer
Predryer
Bl eacher
Rotary steam tube dryer
Type of Control
C/ESP
C/VS
C/ESP
C/VS
-VS
C/ESP
VS
VS
C/ESP
VS
VS
C/ESP
VS
VS
C/ESP
VS
% Reduction
99.92
99.65
99.95
99.94
90.59
99^81
99.74
97.30
99.94
99.87
90.59
99.81
99.74
97.30
99.94
99.87
ro
1S = Small (one train): M = Medium (two trains)
}C = Cyclone; ESP = Electrostatic Precipitator; VS = Venturi Scrubber
-------
control alternative in Table 8-12 are based on emission factors of 0.10
kg/Mg (0.20 Ib/ton) of feed for calciners, 0.04 kg/Mg (0.08 Ib/ton) dry
product for rotary and fluid bed steam tube dryers, D.04 kg/Mg (0.08 Ib/ton)
dry feed for predryers, and 0.02 kg/Mg (0.04 Ib/ton) feed for bleachers.
Sources of data used in the cost analysis were vendor quotes, cost
estimating manuals, and published reports. Vendor quotes were obtained for
the major cost items (electrostatic precipitators, venturi scrubbers, and
26 27 28
cyclones). Cost estimating manuals and published reports ' ' were used
to obtain costs for auxiliary equipment (such as fans, pumps, conveyors,
and duct work), for installation costs, and for indirect costs. Engineering
calculations, vendor data, and published reports were used to estimate
direct operating costs and annualized costs. These data sources will be
discussed in more detail in Sections 8.2.2.1 and 8.2.2.2. Assumptions used
in calculating capital and annualized costs will also be discussed in these
sections.
The factors used for installation costs and indirect costs and the values
used for labor costs were generalized factors, and may be lower than actual
costs that would be incurred in Wyoming because of harsh weather conditions
and high labor rates. However, these factors would affect the costs for
both regulatory alternatives, and thus would not affect the incremental costs
for Alternative 2 over Alternative 1.
Cyclones were included as part of the emission control system for calciners,
fluid bed steam tube dryers, and bleachers for this cost analysis. Cyclones
are considered as part of the emission control system since they lower uncon-
trolled emissions and reduce the particulate load to the subsequent particu-
late removal device (ESP or venturi scrubber) and thus reduce its cost.
Cyclones could also be considered as an integral part of the process used for
economic recovery of product from particulate laden exit gas. In fact, a
cyclone or low energy scrubber would most likely be used for product recovery
even in the absence of air quality regulations. However, since cyclones of
the same efficiency and same cost are used for both control alternatives,
considering cyclones as emission control equipment does not affect the in-
cremental costs for Alternative 2 over Alternative 1.
8-27
-------
8.2.2 New Facilities
Costs for controlling the model plants listed in this section and
discussed in Chapter 6 to the control levels indicated in Section 8.2.1 are
discussed in this section for new facilities. As discussed in Section
8.2.1, two different model plant sizes are considered. The larger (two
train) plant is representative of a new plant. The most recently built
monohydrate process plant and a new plant planned for construction are of
this size. The smaller (one train) plant is representative of an expansion
to an existing plant. As discussed in Chapters 3 and 6, sodium carbonate
plants are typically built and expanded by the construction of essentially
independent processing trains. Costs for emission control for a two train
plant are thus approximately double the costs of a one train plant. For
this reason, control costs are presented in this section for each facility
independently.
8.2.2.1 Capital Costs. Capital cost estimates for each control
system were developed by determining basic equipment costs, and then apply-
ing cost component factors to the basic equipment costs to obtain total
capital costs (including indirects). The capital costs represent the total
investment required for purchase and installation of the basic control
equipment and associated auxiliaries. Costs for research and development
and costs for possible production losses during equipment installation and
start up are not included. All costs are in mid-1979 dollars.
Specifications for the emission control systems are summarized in
Table 8-13. These specifications, along with the emission parameters and
required removal efficiencies presented earlier, were used to calculate
control equipment costs for each facility for each control level. Vendor
29
quotes were obtained for the principal cost items (cyclones, electrostatic
30 31 32 33 34\
precipitators, »*"»" and venturi scrubbers. ' ) Costs for auxiliary
equipment (ductwork, dust conveyors, fans and pumps) were obtained from
nc py
cost estimating manuals. ' These costs were scaled to mid-1979 dollars
using the Chemical Engineering Fabricated Equipment Cost Index.
Component factors used to calculate installation costs and indirect
costs are summarized in Table 8-14. The majority of these factors were
obtained from reference 28. Costs for model studies and start up of an ESP
were obtained from vendors for th
scaled down for the bleacher ESP-
30 31
were obtained from vendors for the calciner ESP. ' These costs were
8-28
-------
TABLE 8-13. SPECIFICATIONS FOR EMISSION CONTROL SYSTEMS
Cyclone/Electrostatic Preci pita tor for Calciner and Bleacher
A. Ducting: 46m (150ft) length with elbows, diameter based on gas
velocity of 15 m/s (3000 ft/min)
B. Dust Removal :
1. Cyclone: 9 inch diameter screw conveyor 23m (75 ft) long; two
for calciner and one for bleacher
2. ESP: Drag conveyor or scraper conveyor at bottom of ESP;
9 inch diameter screw conveyor to carry dust back into pro-
cess, 46m (150 ft) for bleacher and 38m (125 ft) for calciner
C. Pressure drop: 9 cm (3.5 in.) water for cyclone
1 cm (0.5 in.) water for ESP
5 cm (2.0 in.)
water for ductwork
water for c
20 cm (8.0 in. water total
5 cm (2.0 in.) water for calciner or bleacher
(8.0 in.)
D. Power requirement for ESP (total connected power)
1. Bleacher: 80 kw for alt. 1
90 kw for alt. 2
2. Calciner: 480 kw for alt. 1
550 kw for alt: 2
E. Removal Efficiency
1. Cyclone: 80%
2. ESP: 99.62% Calciner alt. 1
99.74% Calciner alt. 2
99.05% Bleacher alt. 1
99.67% Bleacher alt. 2
F. Material of construction: carbon steel
II. Cyclone/Venturi Scrubber for Fluid Bed Steam Tube Dryer
A. Ducting: 46 m (150 ft) length with 4 elbows, diameter based on
gas velocity of 15 m/s (3000 ft/min)
B. Dust Removal for cyclone: one nine inch diameter screw conveyor
15m (50ft) long
C. Pressure drop: 9 cm (3.5 in.) water for cyclone
19 cm (7.5 in.) water for venturi for alt. 1
89 cm (35 in.) water for venturi for alt. 2
5 cm (2 in.) water for ductwork
5 cm (2 in.) water for dryer
8 cm (3 in.) water for demister pad
46 cm (18 in.) water total for alt. 1
116 cm (45.5 in.) water total for alt. 2
8-29
-------
3
D. Liquid to gas ratio: 1.6 Jl/am (12 gal/1000 acfm) inlet
E. Liquid head: 2.8x10 Pa (4 psi) discharge pressure + 6m (20 ft)
water + friction loss for 15 m (50 ft) pipe
F- Removal efficiency
1. Cyclone: 80%
2. Venturi scrubber: 98.25% for alt. 1
99.72% for alt. 2
G. Material of construction: carbon steel
III. Venturi Scrubber for Rotary Steam Tube Dryer
A. Ducting: 38m (125 ft) length with 3 elbows, diameter based on
gas velocity of 15 m/s (3000 ft/min)
B. Pressure drop: 15 cm (6 in.) water for alt. 1 (Wyo.)
38 cm (15 in.) water for alt. 1 (Calif.)
63 cm (25 in.) water for ait. 2
8 cm
5 cm
5 cm
3 in.) water for demister pad
2 in.) water for ductwork
in.
in.)
2 in.) water for dryer
33 cm (13 in.) total for alt. 1 (Wyo.)
56 cm (22 in.) total for aU. 1 (Calif.)
81 cm (32 in.) total for alt. 2
o
C. Liquid to gas ratio: 1.6 &/am (12 gal/1000 acfm) inlet
D. Liquid head: same as cyclone/venturi-scrubber
E. Removal efficiency: 99.18% alt. 1 (Wyo.)
99.74% alt. 1 (Calif)
99.87% alt. 2
F. Material of construction: carbon steel
IV. Venturi Scrubber for Rotary Steam Heated Predryer
A. Ducting: 30m (100 ft) length with 2 elbows, diameter based on a gas
velocity of 15 m/s (3000 ft/min)
B. Pressure drop: 15 cm (6 in.) water for scrubber for alt. 1
30 cm (12 in.) water for scrubber for alt. 2
5 cm (2 in.) water for demister
1 cm (.5 in.) water for ductwork
3 cm (1 in.) water for predryer
24 cm (10 in.) water total for alt. 1
39 cm (16 in.) water total for alt. 2
C. Liguid to gas ratio: 1.6 A/am3 (12 gal/1000 acfm) inlet
D. Liquid head: same as cyclone/venturi scrubber for fluid bed
steam tube dryer
E. Removal Efficiency: 90.59% alt. 1
97.30% alt. 2
F. Material of Construction: carbon steel
8-30
-------
TABLE 8-14. FACTORS USED FOR ESTIMATING INSTALLATION-COSTS AND
INDIRECT COSTS AS A FUNCTION OF PURCHASED EQUIPMENT COST (Q)
ESP
Venturi Scrubber
Instruments and Controls
Taxes
Freight
Purchased equipment cost
(including auxiliaries)
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Model study
Start up
Performance test
Contingencies
Working capital
a
0.03Q
0.05Q
Q
0.04Q1
0.50Q
0.08Q
0.01Q
0.02Q
0.02Q
0.20Q
0.20Q
0.10Q
0.10QC.
0.026Qa
$6000
10% total direct
and indirect
25% total direct
operating cost
0.10Q
0.03Q
0.05Q
Q
0.06Q
0.40Q
0.01Q
0.05Q
0.03Q
0.01Q
0.10Q
0.10Q
0.10Q
0.01Q
$6000
10% total direct
and indirect
25% total direct
operating cost
Included in purchased cost of ESP.
Cyclone supports are calculated separately from reference 27.
cModel study cost based on $20,000 for calciner ESP.
dStart up cost based on $50,000 for calciner ESP.
8-31
-------
Uninstalled costs for control equipment and required auxiliaries are
presented in Table 8-15 for each facility. The components of these equip-
ment costs are presented in Tables 8-16 through 8-27. Installation costs
for each facility are also presented in these tables.
The ESP costs reported in these tables include insulation and all
necessary instrumentation. Cost of the dust removal system is included
with costs for the cyclone dust removal system. A drag bottom ESP is
assumed, with a scraper conveyor at the bottom of the ESP to carry the
collected dust away from the ESP to a screw conveyor, which carries the
dust back into the process. Other auxiliaries for the ESP control system
are a cyclone, ductwork, and a fan.
Venturi scrubber costs reported in these tables include the
scrubber itself, an entrainment separator, and a mist eliminator. Other
auxiliary equipment (ductwork, fan, and pump) is as noted.
Costs for continuous monitoring equipment which would be required under
Alternative 2 are not reported in these tables. These costs are given in
Appendix D, and would be the same for any of the Alternative 2 cases.
Total capital investment requirements (excluding continuous monitoring
costs) for control of emissions are presented in Table 8-28 for each facility
and in Table 8-29 for the entire plants. Capital costs which can be allocated
to NSPS were calculated as the difference in cost between systems controlling
emissions to the NSPS level (Alternative 2) and to the baseline level
(Alternative 1).
As shown in Table 8-28, controlling particulate emissions to Alternative 2
levels would result in an increase in total capital investment ranging from
8 percent (for a bleacher) to 46 percent (for a rotary steam tube dryer) over
costs that would be incurred in meeting Alternative 1. For a plant producing
454,000 Mg/yr (500,000 TPY) of sodium carbonate, total capital investment
required for control of particulate emissions ranges from $1,943,000 to
$4,857,000 (depending on process configuration) for Alternative 1 and from
$2,148,000 to $5,520,000 for Alternative 2 (excluding continuous monitoring
costs). Including continuous monitoring,costs for Alternative 2 would range
from $2,183,000 to $5,548,000. Increase in capital investment required for
meeting Alternative 2 over Alternative 1 ranges from about 12 to 14 percent.
8-32
-------
TABLE 8-15. AIR POLLUTION CONTROL EQUIPMENT COSTS FOR SODIUM CARBONATE PLANTS
Equipment Type
Cyclone/ESP
Cyclone/ESP
Cyclone/ESP
Cyclone/ESP
Venturi scrubber
Venturi scrubber
Venturi scrubber
Venturi scrubber
Cyclone/Venturi scrubber
Cyclone/Venturi scrubber
Venturi scrubber
Venturi scrubber
Inlet
Gas Flow Rate
m3/min
8700
8700
1170
1170
1600
1600
1370
1370
3120
3120
4420
4420
acfm
307,000
307,000
41,210
41,210
56,600
56,600
48,300
4§,300
110,200
110,200
156,000
156,000
Inlet
Particulatp Loadina
g/dm3
119
119
70
70
52
52
52
52
59
59
0.82
0.82
gr/dscf
52
52
30
30
23
23
23
23
26
26
0.36 -
0.36
Removal
Efficiency
99.92
99.95
99.81
99.94
99.18
99.87
99.74
99.87
99.65
99.94
90.59
97.30
Equipment
Cost Mid-
1979$a
1,718,000
1,903,000
506,000
548,000
89,100
128,000
89,200
107,000
240,000
318,000
200,000
220,000
00
I
CJ
CJ
Includes auxiliaries (fans,
not include installation or
pumps, ductwork, conveyors), instrumentation, taxes and freight. Does
indirect costs.
-------
TABLE s-ie. COMPONENT CAPITAL COSTS FOR AN ELECTROSTATIC PRECIPITATOR
FOR CASE la,2a,3a,4a:
Coal-fired Calciner, 99.92%
Component
Purchased Equipment Cost
ESP
Cyclone
Ductwork
Scraper and screw conveyors
Fan, motor and starter, and
damper
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Model study
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
1,210,000
112,000
103,000
87,700
68,200
51,500
85,900
1,718,000
84,700
859,000
137,000
17,200
34,400
34,400
1,167,000
2,885,000
344,000
344,000
172,000
20,000
50,000
6,000
935,000
382,000
4,202,000
99,300
4,301,000
Factor
0.704
0.065
0.060
0.051
0.040
0.03
0.05
1.0
0.049
0.50
0.08
0.01
0.02
0.02
0.68
1.68
0.20
0.20
0.10
0.012
0.029
0.003
0.54
0.22
2.45
0.053
2.50
8-34
-------
TABLE 8-17. COMPONENT CAPITAL COSTS FOR AN ELECTROSTATIC PRECIPITATOR
FOR CASE Ib, 2b, 3b, 4b:
Coal-fired Calciner, 99.95%
Component
Purchased Equipment Cost
ESP
Cyclone
Ductwork
Scraper and screw conveyors
Fan, motor and starter, and
damper
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Model study
•/
Start up
r
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
1,380,000
112,000
103,000
87,700
68,200
57,100
95,100
1,903,000
92,100
951 ,000
152,000
19,000
38,100
38,100
1 ,291 ,000
3,194,000
381 ,000
381 ,000
190,000
20,000
50,000
6,000
1,028,000
422,000
4,664,000
»
106,000
4,750,000
Factor
0.725
0.059
0.054
0.046
0.036
0.03
0.05
1.0
0.048
0.50
0.08
0.01
0.02
0.02
0.68
1.68
0.20
0.20
0.10
0.011
0.026
0.003
0.54
0.22
2.44
0.056
2.50
8-35
-------
TABLE 8-18. COMPONENT CAPITAL COSTS FOR A VENTURI SCRUBBER
FOR CASE la, 2a:
Rotary Steam Tube Dryer, 99.18%
Component
Purchased Equipment Cost
Venturi scrubber, separator,
and mist eliminator
Ductwork
Fan, motor and starter, and
damper
Pump and motor
Instruments and Controls
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
30,000
17,200
21 ,300
4,560
8,910
2,670
4,450
89,100
5,340
38,600
890
4,450
2,670
890
49,900
139,000
8,910
8,910
8,910
890
6,000
33,600
17,300
190,000
26,100
216,000
Factor
0.34
0.19
0.24
0.05
0.10
0.03 -
0.05
1.0
0.06
0.40
0.01
0.05
0.03
0.01
0.56
1.56
0.10
0.10
0.10
0.01
0.067
0.38
0.19
2.13
0.29
2.42
8-36
-------
TABLE 8-19. COMPONENT CAPITAL COSTS FOR A VENTURI SCRUBBER
FOR CASE Ib, 2b:
Rotary Steam Tube Dryer, 99.87%
Component
Purchased Equipment Cost
Venturi scrubber, separator,
and mist eliminator
Ductwork
Fan, motor and starter, and
damper
Pump and motor
Instruments and Controls
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
30 ,000
17,200
Factor
Of\*\
.23
0.13
53,200
4,560
12,800
3,840
6,400
128,000
7,680
51 ,200
1,280
6,400
3,840
1,280
71 ,600
200,000
12,800
12,800
1 2 ,800
1,280
6,000
45,700
24,500
270,000
46,200
316,000
0.42
0.036
0.10
0.03
0.05
1.0
0.06
0.40
0.01
0.05
0.03
0.01
0.56
1.56
0.10
0.10
0.10
0.01
0.047
0.36
0.19
2.11
0.36
2.47
8-37
-------
TABLE 8-20. COMPONENT CAPITAL COSTS FOR A VENTURI SCRUBBER
FOR CASE 5a, 6a:
Rotary Steam Tube Dryer, 99.74%
Component
Purchased Equipment Cost
Venturi scrubber, separator,
and mist eliminator
Ductwork
Fan, motor and starter, and
damper
Pump and motor
Instruments and Controls
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
w
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Start up
t
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
30,000
15,000
23,900
4,270
8,920
2,680
4,460
89,200
5,350
35,700
890
4,460
2,680
890
50,000
139,000
8,920
8,920
8,920
890
6,000
33,700
17,300
190,000
32,300
222,000
Factor
0.34
0.17
0.27
0.048
0.10
0.03-
0.05
1.0
0.06
0.40
0.01
0.05
0.03
0.01
0.56
1.56
0.10
0.10
Ov j^
.10
0.01
0.067
0.38
0.19
2.13
0.36
2 /in
.49
8-38
-------
TABLE 8-21.
COMPONENT CAPITAL COSTS FOR A VENTURI SCRUBBER
FOR CASE 5b, 6b
Rotary Steam Tube Dryer, 99.87%
Component
Purchased Equipment Cost
Venturi scrubber, separator,
and mist eliminator
Ductwork
Fan, motor and starter, and
damper
Pump and motor
Instruments and Controls
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
<&
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
30,000
15,000
38,400
4,270
10,700
3,210
5,340
107,000
6,410
42,800
1,070
5,340
3,210
1,070
59,900
167,000
10;700
10,700
10,700
1,070
6,000
39,100
20,600
226,000
41 ,200
268,000
Factor
0.28
0.14
0.36
0.04
0.10
0.03
0.05
1.0
0.06
0.40
0.01
0.05
0.03
0.01
0.56
1.56
0.10
0.10
0.10
0.01
0.056
0.37
0.19
2.10
0.39
2.50
8-39
-------
TABLE 8-22. COMPONENT CAPITAL COSTS FOR A VENTURI SCRUBBER
FOR CASE 3a, 4a:
Fluid Bed Steam Tube Dryer, 99.65%
Component
Purchased Equipment Cost
Venturi scrubber, separator,
and mist eliminator
Cyclone
Ductwork
Screw conveyors
Fan, motor and starter, and
damper
Pump and motor
Instruments and Controls
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
i
Construction fee
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
50,000
56,000
30,500
3,800
50,600
6,000
24,000
7,200
12,000
240,000
22,200
96,000
2,400
12,000
7,200
2,400
142,000
382,000
24,000
24,000
24,000
2,400
6,000
80,400
46,300
509,000
47,100
556,000
Factor
0.21
0.23
0.13
0.016
. — .
0.21
0.025
0.10
0.03
0.05
1.0
0.093
0.40
0.01
0.05
0.03
0.01
0.59
1.59
0.10
0.10
0.10
0.01
0.025
0.34
0.19
2.12
0.20
2.32
8-40
-------
TABLE 8-23. COMPONENT CAPITAL COSTS FOR A VENTURI SCRUBBER
FOR CASE 3b, 4b:
Fluid Bed Steam Tube Dryer, 99.94%
Component
Purchased Equipment Cost
Venturi scrubber, separator,
and mist eliminator
Cyclone
Ductwork
Screw conveyors
Fan, motor and starter, and
damper
Pump and motor
r
Instruments and Controls
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
*j
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
50,000
56,000
30,500
3,800
115,000
6,000
31 ,800
9,550
15,900
318,000
26,900
127,000
3,180
15,900
9,550
3,180
186,000
504,000
31 ,800
31 ,800
31 ,800
3,180
6,000
105,000
60,900
670,000
99,700
770 ,000
Factor
0.16
0.18
0.096
0.012
0.36
0.019
0.10
0.03
0.05
1.0
0.085
0.40
0.01
0.05
0.03
0.01
0.58
1.58
0.10
0.10
0.10
0.01
0.019
0.33
0.19
2.11
0.31
2.42
8-41
-------
TABLE 8-24.
COMPONENT CAPITAL COSTS FOR AN ELECTROSTATIC PRECIPITATOR
FOR CASE 5a,6a
Bleacher, 99.81%
Component
Purchased Equipment Cost
ESP
Cyclone
Ductwork
Scraper and screw conveyors
Fan, motor and starter, and
damper
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
r w
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Model study
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
364,000
17,000
28,500
46,100
9,710
15,200
25,300
506,000
22,900
253,000
40,400
5,060
10,100
10,100
342,000
848,000
101,000
101,000
50,600
6,000
15,000
6,000
280,000
113,000
1,241,000
18,900
1,260,000
Factor
0.72
0.034
0.056
0.091
0.019
0.03
0.05
1.0
0.045
0.50
0.08
0.01
0.02
0.02
0.68
1.68
0.20
0.20
0.10
0.012
0.029
0.012
0.55
0.22
2.45
0.037
2.49
8-42
-------
TABLE 8-25.
COMPONENT CAPITAL COSTS FOR AN ELECTROSTATIC PRECIPITATOR
FOR CASE 5b,6b
Bleacher, 99.94%
Component
Purchased Equipment Cost
ESP
Cyclone
Ductwork
Scraper and screw conveyors
Fan, motor and starter, and
damper
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Model study
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
403,000
17,000
28,500
46,100
9,710
16,400
27,000
548,000
24,600
274,000
43,800
5,500
11,000
11,000
370,000
918,000
110,000
110,000
54,800
6,000
15,000
6,000
301 ,000
122,000
1,341,000
19,900 -
1,360,900
Factor
0.74
0.031
0.052
0.084
0.018
0.03
0.05
1.0
0.045
0.50
0.08
0.01
0.02
0.02
0.02
1.68
0.20
0.20
0.10
0.012
0.029
0.011
0.55
0.22
2.45
0.036
2.48
8-43
-------
TABLE 8-26.
COMPONENT CAPITAL COSTS FOR A VENTURI SCRUBBER
FOR CASE 5a, 6a
Predryer, 90.59%
Component
Purchased Equipment Cost
Venturi scrubber, separator,
and mist eliminator
Ductwork
Fan, motor and starter, and
damper
Pump and motor
Instruments and Controls
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
63 ,000
38 ,800
' 54 ,500
8,000
20,000
6,000
10,000
.200,000
12,000
80,200
2,000
10,000
6,000
2,000
112,000
313,000
20 ,000
20 ,000
20 ,000
2,000
6,000
68 ,1 00
38 ,000
A ^ f\
419,000
42 ,300
461 ,000
Factor
0.32
0.19
0.27
0.040
0.10
0.03
0,05
1.00
0.060
0.40
0.010
0.050
0.030
0.010
0.56
1.56
0.100
0.100
0.100
0.010
0.03
0.34
0.19
2.09
0.21
2.31
8-44
-------
TABLE 8-27.
COMPONENT CAPITAL COSTS FOR A VENTURI SCRUBBER
FOR CASE 5b, 6b
Predryer, 97.30%
Component
Purchased Equipment Cost
Venturi scrubber, separator,
and mist eliminator
Ductwork
Fan, motor and starter, and
damper
i
Pump and motor
Instruments and Controls
Taxes
Freight
TOTAL EQUIPMENT COST = Q
Direct Installation Costs
Foundations and supports
Erection and handling
Electrical
Piping
Insulation
Painting
TOTAL
TOTAL DIRECT COSTS
Indirect Costs
Engineering and supervision
Construction and field expense
Construction fee
Start up
Performance test
TOTAL INDIRECT COST
Contingency
TOTAL TURNKEY COST
Working Capital
GRAND TOTAL
Cost, Mid-1979 $
63,000
38,800
70,200
8,000
22,000
6,600
11,000
220,000
13,200
87,800
2,200
11,000
6,590
2,200
123,000
343,000
22,000
22,000
22,000
2,200
6,000
74, 100
41 , 700
458,000
60,700
519,000
Factor
0.29
0.18
0.32
0.036
0.100
0.030
0.050
1.00
0.06
0.40
0.010
0.050
0.030
0.010
0.56
1.56
0.100
0.100
0.100
0.010
0.011
0.34
0.19
2.09
0.28
2.36
8-45
-------
CO
I
-pi
cr>
TABLE 8-28. TOTAL CAPITAL INVESTMENT FOR CONTROL OF PARTICULATE EMISSIONS FROM FACILITIES
IN SODIUM CARBONATE PLANTS
Facility
Coal -fired
Cal drier
Rota , steam tube
dryer - Wyo.
Rotary steam tube
dryer - Calif.
Fluid bed steam
tube dryer
Bleacher
Predryer
Typt of
Control
C/ESP
VS
VS
C/VS
C/ESP
•VS
Participate
kg/Mg
0.15
0.25
0.08
0.25
0.06
0.14
1 EByip
HL i . c
kg/Mg
0.10
0.04
0.04
0.04
0.02
0,04
ALT, 1
99.92
99.18
99.74
99.65
99.81
90.59
ALT. 2
99.95
99.87
99.87
99.94
99.94
97.30
Total Insttll«d C«o1Ul
ALT. 1
4,301,000
216,000
222,000
556,000
1,260,000
461 ,000
ALT. 2
4,750.000
316,000
268,000
770,000
1 ,361 .000
519,000
INCREASE FOB ALT. 2
OVER ALT. 1
$
449,000
*•
100,000
46,000
214,000
101 ,000
58,000
%
10
46
21
38
8
13
aC/ESP = Cyclone/ESP
C/VS =• Cyclone/Venturl scrubber
VS * Venturl scrubber
Hota! turnkey system costs and working capital, Md-1979 cost basis. Costs for continuous monitoring
not Included.
-------
TABLE 8-29. TOTAL CAPITAL INVESTMENT FOR CONTROL OF PARTICULATE
EMISSIONS FROM MODEL SODIUM CARBONATE PLANTS3
do
Number
1
2
3
4
5
6
Plant size
Small
Medium
Small
Medium
Small
Medium
Configuration
1
1
2
2
3
3
Process
Monohydrate
Monohydrate
Monohydrate
Monohydrate
Direct
carbonation
Direct
carbonation
Alt. 1
$4,517,000
9,034,000
4,857,000
9,714,000
1,943,000
3,886,000
Alt. 2
$5,094,000
10,190,000
5,548,000
11,100,000
2,183,000
4,366,000
Cost Increase for Alt. 2
over Alt. 1
$
577,000
1,153,000
691 ,000
1 ,381 ,000
240,000
480,000
%
12.8
12.8
14.2
14.2
12.3
12.3
Total turnkey system costs and working capital, mid-1979 cost basis. Costs for continuous
monitoring are included.
-------
8.2.2.2 Annualized Costs. Annualized costs represent the cost of
operating and maintaining a pollution control system plus the cost of
recovering the capital investment required for the system. The bases used
in calculating annualized costs are summarized in Tables 8-30, 8-31, and
8-32. Utlity requirements were calculated based on the control system
specifications given in Table 8-13. A 60 percent efficiency was assumed
for pumps and fans.
A credit was assigned to the particulates removed by the control
systems based on the values presented in Table 8-32. These values are
based on a value of $8.82/Mg ($8/ton) for raw trona ore. This is the
value assigned by the State of Wyoming Department of Revenue for tax
purposes. Particulates recovered from the calciner are assumed to have
the value of the raw trona ore plus the cost of energy for calcination.
Particulates removed in the dryer scrubbers are recovered in an aqueous
solution from which they must be recrystallized and re-dried. These
particulates are assumed to have the value of an equivalent amount of
calcined ore. Particulates recovered from the bleacher must undergo a
comparable degree of processing (dissolution, crystallization, drying) and
thus are assumed to have the same value as particulates removed in the
dryer scrubbers. No product credit was given to particulates removed in
the bleacher ESP since these are sometimes discarded rather than being
returned to the process.
Components of the annualized costs for each control system are pre-
sented in Tables 8-33 through 8-44. Annualized costs for all the control
systems are summarized in Table 8-45 for each facility, and in Table 8-46
for the entire plants. These tables do not include costs for continuous
monitoring. The monitoring costs are reported in Appendix D.
As shown in Table 8-46, annualized costs for control of particulate
emissions from a plant producing 454,000 Mg/yr (500,000 TPY) sodium carbonate
range from a credit of $2,061,000 to a cost of $305,000 under Alternative 1,
and from a credit of $1,724,000 to a cost of $455,000 under Alternative 2
(excluding monitoring costs). Including monitoring costs, annualized costs
under Alternative 2 would range from a credit of $1,712,000 to a cost of
$471,000. The increase in annualized costs for Alternative 2 over Alter-
native 1 is about 17 to 54 percent (including continuous monitoring).
8-4P
-------
TABLE 8-30. BASES FOR ANNUALIZED COSTS OF AIR
POLLUTION CONTROL SYSTEMS
Item
Operating hours (hr/yr)
Direct Operating labor (hr/shift)
Maintenance labor (hr/shift)
Equipment life (years)
Interest rate (%)
Capital recovery factor
(% of Total Turnkey Cost)
ESP
7446
1
0.5
20
12
13.4
Venturi Scrubber
7446
2
1
10
12
17.7
TABLE 8-31. ITEMS USED IN COMPUTING TOTAL ANNUALIZED COSTS
Item
Unit Value
Direct Operating Labor
Supervision
Maintenance labor
Maintenance materials3
Uti1i ti es ^
Electricity
Process water
Overhead
G&A, taxes, and insurance
Interest on working capital
$8.80/hr
15% of direct labor
$9.70/hr
100% of maintenance labor
$0.048/kwh
$0.074/m3 ($0.28/1000 gal)
80% of operating labor & supervision and
maintenance labor
4% of Total Turnkey Costs
12% of working capital
For venturi scrubber, add $4000 (for larger scrubber) or $3000 (for smaller
scrubber) for replacement parts.
Multiply calculated value by 1.1 to account for line losses.
8-49
-------
TABLE 8-32. RECOVERY CREDITS FOR PARTICULATES REMOVED
IN POLLUTION CONTROL SYSTEMS
Facility/Removal Device
Credit for R
$/Mg
^covered Product
$/ton
Coal-fired Calciner
Cyclone
ESP
Bleacher
Cyclone
ESP
Fluid bed steam tube dryer
Cyclone
Venturi Scrubber
Rotary steam tube dryer
Venturi Scrubber
Predryer
Venturi scrubber
9.55
9.55
16.30
None
67
16.30
16.30
None
8.66
8.66
14.80
None
61
14.80
14.80
None
8-50
-------
TABLE 8- 33.
COMPONENT ANNUALIZED COSTS FOR AN ELECTROSTATIC
PRECIPITATOR FOR CASE la,2a,3a,4a
Coal-fired Calciner, 99.92%
Component
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
TOTAL DIRECT COSTS
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
TOTAL ANNUALIZED COSTS
(without product recovery)
Credit for parti cul ate recovery
Cyclone
ESP
TOTAL CREDIT
NET ANNUALIZED COSTS
(annual ized costs-credit)*
Cost, Mid-1979$ per year
9,420
9,020
379,000
397,000
11,100
172,000
576,000
11,900
771 ,000
1,169,000
1,305,000
325,000
1,630,000
- 461,000
*A negative value indicates a net credit
8-51
-------
TABLE 8-34. COMPONENT ANNUALIZED COSTS FOR AN ELECTROSTATIC
PRECIPITATOR FOR CASE lb,2b,3b,4b:
Coal-fired Calciner, 99.95%
Component
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
TOTAL DIRECT COSTS
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
TOTAL ANNUALIZED COSTS
(without product recovery)
Credit for parti cul ate recovery
Cyclone
ESP
TOTAL CREDIT
NET ANNUALIZED COSTS
(annual ized costs-credit)*
Cost, Mid-1 979$ per year
9,420
9,020
406,000
424,000
11,100
186,000
622,000
12,700
832,000
1,256,000
1,305,000
325,000
1 ,631 ,000
-374,000
*A negative value indicates a net credit
8-52
-------
TABLE 8-35. COMPONENT ANNUALIZED COSTS FOR A VENTURI
SCRUBBER FOR CASE la,2a
Rotary Steam Tube Dryer, 99.18%
Component
Cost, Mid-1979 $ per year
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
Process water
TOTAL DIRECT COSTS
18,900
21,100
58,200
6,620
104,000
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
22,300
7,590
33,600
3,130
66,600
TOTAL ANNUALIZED COSTS
(without product recovery)
171,000
Credit for particulate recovery
Venturi scrubber
TOTAL CREDIT
234,000
NET ANNUALIZED COSTS
(annualized costs-credit)*
-63,000
*A negative value indicates a net credit
8-53
-------
TABLE 8-36.
COMPONENT ANNUALIZED COSTS FOR A VENTURI
SCRUBBER FOR CASE lb,2b:
Rotary Steam Tube Dryer, 99.87%
Component
Cost, Mid-1979 $ per year
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
Process water
TOTAL DIRECT COSTS
18,900
21,100
138,000
6,260
185,000
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
22,300
10,800
47,800
5,540
66,000
TOTAL ANNUALIZED COSTS
(without product recovery)
271,000
Credit for particulate recovery
Venturi scrubber
TOTAL CREDIT
236,000
NET ANNUALIZED COSTS
(annualized costs-credit)*
35,500
*A negative value indicates a net credit
8-54
-------
TABLE 8-37. COMPONENT ANNUALIZED COSTS FOR A VENTURI
SCRUBBER FOR CASE 5a,6a
Rotary Steam Tube Dryer, 99.74%
Component
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
Process water
TOTAL DIRECT COSTS
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
TOTAL ANNUALIZED COSTS
(without product recovery)
Credit for particulate recovery
Venturi scrubber
TOTAL CREDIT
NET ANNUALIZED COSTS
(annual ized costs-credit)*
Cost, Mid-1979 $ per year
18,900
21..100
83,100
6,260
129,000
22,300
7,600
33,600
3,880
67,400
197,000
235,000
-38,500
*A negative value indicates a net credit
8-55
-------
TABLE 8-38. COMPONENT ANNUALIZED COSTS FOR A VENTURI
SCRUBBER FOR CASE 5b,6b
Rotary Steam Tube Dryer, 99.87%
Component
Cost, Mid-1979 $ per year
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
Process water
TOTAL DIRECT COSTS
18,900
21,100
119,000
6,260
165,000
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
22,300
9,060
40,100
4,950
76,400
TOTAL ANNUALIZED COSTS
(without product recovery)
241,000
Credit for particulate recovery
Venturi scrubber
TOTAL CREDIT
236,000
NET ANNUALIZED COSTS
(annualized costs-credit)*
5,820
*A negative value indicates a net credit
8-56
-------
TABLE 8- 3a COMPONENT ANNUALIZED COSTS FOR A VENTURI
SCRUBBER FOR CASE 3a,4a
Fluid Bed Steam Tube Dryer, 99.65%
Component
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
Process water
TOTAL DIRECT COSTS
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
TOTAL ANNUAL I ZED COSTS
(without product recovery)
Credit for parti cul ate recovery
Cyclone
Venturi scrubber
TOTAL CREDIT
NET ANNUALIZED COSTS
(annual ized costs-credit)*
Cost, Mid 1979$ per year
18,900
22,100
143,000
4,380
189,000
22,300
20,400
90,100
5,660
138,000
327,000
1,820,000
109,000
1,930,000
-1,600,000
*A negative value indicates a net credit
8-57
-------
TABLE 8-40. COMPONENT ANNUALIZED COSTS FOR A VENTURI
SCRUBBER FOR CASE 3b,4b
Fluid Bed Steam Tube Dryer, 99.94%
Component
Cost, Mid 1979$ per year
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
Process water
TOTAL DIRECT COSTS
18,900
22,100
354,000
4,380
399,000
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
22,300
26,800
119,000
12,000
179,000
TOTAL ANNUALIZED COSTS
(without product recovery)
578,000
Credit for parti cul ate recovery
Cyclone
Venturi scrubber
TOTAL CREDIT
1,820,000
110,000
1,930,000
NET ANNUALIZED COSTS
(annual!zed costs-credit)*
-1,350,000
*A negative value indicates a net credit
8-58
-------
TABLE 8-41.
COMPONENT ANNUALIZED COSTS FOR AN ELECTROSTATIC
PRECIPITATOR FOR CASE 5a, &a
Bleacher - 99.81%
Component
Cost, Mid-1979$ per year
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
TOTAL DIRECT COSTS
9,420
9,020
57,000
75,400
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
11,100
49,600
166,000
2,300
229,000
TOTAL ANNUALIZED COSTS
(without product recovery)
305,000
Credit for particulate recovery
Cyclone
ESP
TOTAL CREDIT
250,000
None
250,000
NET ANNUALIZED COSTS
(annualized costs-credit)*
55,000
*A negative value indicates a net credit
8-59
-------
TABLE 8-42,
COMPONENT ANNUAL I ZED COSTS FOR AN ELECTROSTATIC
PRECIPITATOR FOR CASE 5b, 6b
Bleacher - 99.94%
Component
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
TOTAL DIRECT COSTS
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
TOTAL ANNUALIZED COSTS
(without product recovery)
Credit for particulate recovery
Cyclone
ESP
TOTAL CREDIT
NET ANNUALIZED COSTS
(annual ized costs-credit)*
Cost, Mid-1979$ per year
9,420
9,020
61 ,000
79,400
11,100
53,600
180,000
2,400
247,000
326,000
250,000
None
250,000
77,000
*A negative value indicates a net credit
8-60
-------
TABLE 8-4a
COMPONENT ANNUALIZED COSTS FOR A VENTURI
SCRUBBER FOR CASE 5a,6a
Predryer, 90.59%
Component
Cost, Mid 1979$ per year
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
Process water
TOTAL DIRECT COSTS
18,800
22,100
125,000
3,340
169,000
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
22,300
16,800
74,100
5,080
118,000
TOTAL ANNUALIZED COSTS
(without product recovery)
288,000
Credit for particulate recovery
Venturi scrubber
TOTAL CREDIT
None
None
NET ANNUALIZED COSTS
(annualized costs-credit)*
288,000
*A negative value indicates a net credit
8-61
-------
TABLE 8-44.
COMPONENT ANNUALIZED COSTS FOR A VENTURI
SCRUBBER FOR CASE 5b,6b
Predryer, 97.30%
Component
Cost, Mid 1979$ per year
Direct Costs
Operating labor and supervision
Maintenance labor and materials
Utilities
Electricity
Process water
TOTAL DIRECT COSTS
18,800
22,100
198,000
3,340
243,000
Overhead
Capital Charges
G&A, taxes, and insurance
Capital recovery charges
Interest on working capital
TOTAL CAPITAL CHARGES AND OVERHEAD
TOTAL ANNUALIZED COSTS
(without product recovery)
22,300
18, 300
81,100
7,280
129,000
372,000
Credit for particulate recovery
Venturi scrubber
TOTAL CREDIT
None
None
NET ANNUALIZED COSTS
(annualized costs-credit)*
372,000
*A negative value indicates a net credit
8-62
-------
TABLE 8-45. ANNUALIZED COSTS FOR CONTROL OF PARTICIPATE EMISSIONS FROM FACILITIES
IN SODIUM CARBONATE PLANTS
Facility
Coal -fired
calciner
Coal -fired
calciner
Rotary steam-tube
dryer
Rotary steam-tube
dryer
Rotary steam- tube
dryer
Rotary steam- tube
dryer
Fluid bed steam
tube dryer
Fluid bed steam
tube dryer
Bleacher
Bleacher
Predryer
Predryer
Type of b
Control
C/ESP
C/ESP
VS
VS
VS
VS
C/VS
c/vs
C/ESP
C/ESP
VS
VS
Particulate
Removal
%
99.92C
99.95
99.18C
99.87
99.74C
99.87
99.65C
99.94
99.81C
99.94
90 . 59C
97.30
Direct Costs
$/yr
379,000
424,000
104,000
1P5,000
129,000
165,000
189,000
399,000
75,400
79,400
169,000
243,000
Capital. Charges
and Overhead
$/yr
754,000
832,000
-
66,600
86,400
67,400
76,400
138,000
179,000
229,000
247,000
118,000
129,000
Total
Annual i zed
Cost $/yr
1,133,000
1.256,000
171,000
271,000
197,000
241,000
327,000
578,000
305,000
326,000
288,000
372,000
Net .
Annual i zed Cost
$/yr
( 461,000)
(374,000)
(63,000)
35,500
(38,500)
5820
(1,600,000)
(1,350,000)
55,000
77,000
288,000
372,000
oo
(T>
CO
aAll costs are in mid-1979$.
monitoring are not included
bC/ESP = Cyclone/ESP; C/VS =
VS = Venturi scrubber
Costs for continuous
Cyclone/Venturi scrubber;
'Denotes baseline case.
Including recovery credit. Values in
parentheses are net credits.
-------
TABLE 8-46. ANNUALIZED COSTS FOR CONTROL OF PARTICULATE EMISSIONS
FROM MODEL SODIUM CARBONATE PLANTS3
Number
1
2
3
4
5
6
Plant size
Small
Medium
Small
Medium
Small
Medium
Configuration
1
1
2
2
3
3
Process
Mo no hydrate
Mono hydrate
Mo no hydrate
Mono hydrate
Direct
Carbonation
Direct
Carbonation
Alt. 1
$ (524,000)
(1,050,000)
(2,061,000)
(4,122,000)
305,000
609,000
Alt. 2
$ (327,000)
(653,000)
(1,712,000)
(3,423,000)
471,000
941 ,000
Cost Incn
Alt. 1 ov{
$
197,000
395 ,000
349,000
699 ,000
166,000
3.31,000
*ase from
ur Alt. 2
%
38
38
17
17
54
54
00
aCosts are net annualized costs (including recovery credits) in mid-1979 $ per year.
Values in parentheses are net credits. Costs for continuous monitoring are included.
-------
8.2.2.3 Cost Comparison. In this section, estimates of control system
costs derived from different sources will be compared. Estimates of total
turnkey system costs, however, are difficult to compare, because direct and
indirect installation costs are quite variable, and it is frequently diffi-
cult to determine what components are included in a given estimate. It is
thus difficult to compare costs of installed systems on a consistent basis.
For these reasons, only costs for the major items of purchased equipment will
be compared in this section.
on 01 39
Costs for electrostatic precipitators were obtained from vendors ''
35
from a cost estimating manual, and from industry data, ihe costs from
these sources are summarized in Table 8-47. As shown, cost estimates for
the larger ESP obtained from different vendors are similar, but costs
obtained from the estimating manual are significantly lower. The higher
of the vendor estimates was used in the cost analysis. For the smaller
ESP, the cost estimates show a much wider variation. The ESP in this case
is fairly small', and design engineering costs can thus be excessive. The
middle value of the three vendor quotes was used in the cost analysis.
33 34
Costs for venturi scrubbers were obtained from vendors ' and from
^fi
a cost estimating manual. The costs from these sources are summarized
in Table 8-48. Vendors indicated that the cost of the scrubber itself
would be the same for the different control levels. Cost of the fan,
however, would change because of the difference in scrubber pressure drop.
As shown, the cost estimates from the three sources compare favorably.
The higher of the vendor quotes was used in the cost analysis.
8.2.2.4 Cost Effectiveness. Two parameters that are often used in
evaluating the cost of pollution control systems are cost effectiveness
and marginal cost effectiveness. Cost effectiveness is defined as the
total annualized cost of the pollution control system divided by the
quantity of pollutant removed by the system. Marginal cost effectiveness
is the incremental annualized cost per unit of pollutant removed above an
arbitrary baseline. In this analysis, marginal cost effectiveness was
calculated as follows:
8-65
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TABLE 8-47. COMPARISON OF COST ESTIMATES OF ELECTROSTATIC PRECIPITATORS
3Gas flow rate
m /min (acfm)
8700 (307,000)
8700 (307,000)
1170 (41,210)
1170 (41,210)
Removal efficiency
%
99.62
99.74
99.05
99.67
F.
Vendor #1
l,210,000a
l,380,000a
100,000a
130,000a
p.B. cost estim
Vendor #2
l,200,000a'b
l,200,000a'b
500,000a'e
500,000a>e
ates. 1979 $
Vendor #3 or
Industry Data
857,000d
366,000a'f
405,000a'f
Cost Manual
590,000C
599,000C
217,000°
230,000C
00
a\
cr»
aVendor quote, references 30, 31, 32.
Includes cost for support steel not included in other estimates (^$50,000)
Reference 35. updated to mid-1979 $
Industry data, updated to mid-1979 $
elncludes costs for support steel and freight not included in other estimates (^$45,000)
Includes cost for screw conveyor not included in other estimates (^$2000)
-------
TABLE 8-48. COMPARISON OF COST ESTIMATES OF VENTURI SCRUBBERS
Gas Flow Rate
m-Vmin (acfm)
1600 (56,600)
3120 (110,200)
4420 (156,000)
FOB Cost Estimates, 1979$a
Vendor #1
30,000b
50,000b
63,000b
Vendor #2
26,131b
45,493b
Cost Manual
26,000C
50,000C
59,000C
Includes venturi scrubber, entrainment separator, and mist
eliminator. Does not include pump or fan.
Vendor quote, references 33, 34, 36.
Reference 37 updated to 1979$.
,8-67
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MCE = C2 " C[
P - P
VZ "B
where MCE = Marginal cost effectiveness
C2 = Net annualized cost to remove a quantity of pollutant P«
CB = Net annualized cost to remove a quantity of pollutant PB
to meet a specified baseline level
Cost effectiveness and marginal cost effectiveness for the control options
considered in this analysis are presented in Table 8-49.
The overall marginal cost effectiveness for a small monohydrate plant
ranged from $1.41/kg of particulates removed ($1280/ton) to $2.50/kg
($227Q/ton). The marginal cost effectiveness at a small direct carbonation
plant was about $,1.40/kg ($]27tyton).
As noted in Section 8.2.1, a cyclone was included as part of the
control system for the calciner, bleacher, and flutd bed dryer.
Inclusion of the cyclone in the control system costs has two major impacts
on the cost analysis. First, because such a large mass of material is .
recovered in the cyclone at a low cost, inclusion of a recovery credit for
material recovered in the cyclone in the total annualized costs for a
control system offsets,much of the direct operating costs and capital
charges for the control system. In some cases, the resultant net annualized
cost is actually a credit. Since the value of material recovered in the
cyclone is generally greater than the annualized cost of the cyclone,
inclusion of the cyclone recovery credit in the total costs of the emission
control system leads to an offset of the cost of the other control devices
(ESP or venturi scrubber) because of recovery credit from the cyclone.
This can produce misleading results, especially since in many cases a
cyclone would be an integral part of the process even in the absence of
air quality regulations. For similar reasons, inclusion of the cyclone
in the control system cost strongly impacts the cost effectiveness calcula-
tion. A large mass of particulates are removed in the cyclone at a low
cost, while a relatively small mass are removed in the venturi scrubber or
ESP at a higher cost. Thus, the combined cost effectiveness is somewhat
misleading.
8-68
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TABLE 8-49<
COST EFFECTIVENESS OF CONTROL OF PARTICULATE EMISSIONS FROM
SODIUM CARBONATE PLANTS
Facility
Coal -fired calciner
Coal -fired calciner
Rotary steam tube dryer
Rotary steam rube dryer
Rotary steam tube dryer
Rotary steam tube dryer
Fluid bed steam tube dryer
Fluid bed steam tube dryer
Bleacher
Bleacher
Predryer
Predryer
Type of
Control3
C/ESP
C/ESP
VS
VS
VS
VS
C/VS
C/VS
C/ESP
C/ESP
VS
VS
Parti cul ate
Removal
%
99.92b
99^95
99.18b
99.87
99o74b
99o87
99.65b
99.94
99o81b
99o94
90.59b '
97.30
Cost Effectiveness
Excluding Re-
covery credits
$/kg
0.0068
0.0074
0.012
0.019
0.014
0.017
0.0097
0.017
0.016
0.018
0.244
0.297
$/ton
6.21
6.72
'10.8
17.2
12.4
15.4
8.81
15.6
14.5
15.9
221
270
Including Re- .
co very credits
$/kg
(0.0027)
(0.0021)
(0.044)
0.0027
(0.0027)
0.00063
(0.048)
(0.04)
0.0029
0.0045
0.244
0.297
$/ton
(2.45)
(1.94)
(3.98)
2.44
'(2.42)
0.573
(43,1)
(36,2)
2,62
4,08
221
270
Marginal
Cost Effectiveness
Relative to baseline
$/kg
_b
2.35
_b
1.04
b
«w
2.50
_b
2.56
_b
1,28
_b
0.923
$/ton
-
2130
.
925
2270
mm
2320
1157
837
00
I
fC/ESP = Cyclone/ESP
C/VS = Cyclone/Venturi scrubber
VS = Venturi scrubber
denotes baseline case
'Total annualized cost
Kg(ton) particulates removed
Values in parentheses indicate credits
6Tota1 (or net) annualized cost - Total (or net) annualized cost for baseline
kg(ton) particulates removed - kg(ton) particulates removed for baseline
-------
The effect of inclusion of the cyclone in the control system costs is
L
demonstrated in Table 8-50, where cost effectiveness for the ESP without
the cyclone is calculated. As shown, the cost effectiveness of the ESP is
$0.033/kg, compared to $0.0074/kg for the cyclone/ESP (excluding recovery
credits).
Neither of these impacts, however, affects the calculation of Incre-
mental costs or marginal cost effectiveness. Since the cost of the cyclone
and the mass of the particulates removed in the cyclone are the same for both
alternatives, the effects of the cyclone are subtracted out in the calculation
of marginal cost effectiveness.
8.2.2.5 Base Cost of Facilities. The emission sources considered in
this study do not comprise the entire sodium carbonate plant; therefore,
costs for each facility in addition to costs for a complete sodium
carbonate plant are presented.
The capital costs and the annualized operating costs for the un-
controlled facilities are presented in Table 8-51. Capital costs include
purchased cost, installation cost, and indirect cost of the facilities and
auxiliary equipment. Total capital investment for a new plant producing
907,000 Mg/yr (1 million TPY) of sodium carbonate is about $280,000,000
including mine or well facilities.
-------
TABLE 8-50. COST EFFECTIVENESS OF PARTICULATE REMOVAL
FOR ELECTROSTATIC PRECIPITATOR COMPARED TO
CYCLONE/ELECTROSTATIC PRECIPITATOR
Cost Effectiveness
Cyclone/ESP
ESP
Excluding Recovery Credits
$/kg
$/ton
Including Recovery Credits
$/kg
$/ton
0.0074
6.67
(0.0022)'
(1.99)a
0.033
29.6
0.0231
20.9
Net credit
8-71
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TABLE 8-510 UNCONTROLLED FACILITY COSTS'
Facility
Coal -fired Calciner
Rotary steam
tube dryer
Fluid bed steam
tube dryer
Predryer0
Bleacher
Feed Rate
Mg/hr TPH
118
64b
64b
118
82
130
70b
70b
130
90
Total Installed
Capital Cost $
2,520,000
2,490,000
1,990,000
2,890,000
1,510,000
Direct Operating
Cost $/yr
1,190,000
3,460,000
3,267,000
1 ,430,000
426,000
Capital Charges
and overhead
$/yr
752,000
537,000
373,000
4
588,000
299,000
Total Annual
Operating Cost
$/yr
1,940,000
4,000,000
3,630,000
2,020,000
724,000
00
•vl
ro
All costs are in mid-1979$.
}Dry product.
'Data are for 2 predryers.
-------
The capital costs of SIP controls are not included in the values re-
ported in Table 8-51. These costs are presented in Section 8.2.2.1 (Alter-
native 1).
Annualized operating costs include the following:
utilities
maintenance
operating labor and supervision
the annualized capital cost.
The value of the feed material to each of the facilities is based on
the operating cost of equipment "upstream" of the facilities. In many
cases, this "upstream equipment" is another facility. Thus, to avoid
including the operating cost of one facility in the operating cost of
another facility, the cost of the feed material to each facility is not
included in the annual operating cost.
Utility costs for the uncontrolled facilities are based on energy
usage values presented in Chapter 3, and estimates of the electrical
requirements to operate the facility. The cost factor assumed for each
form of energy is presented in Table 8-52.
Maintenance costs were estimated on the basis of factors presented in
Perry's Chemical Engineers Handbook^ and information reported in reference
43. Maintenance costs include maintenance parts and labor.
Operating labor and supervision were estimated on the basis of factors
38
reported in Perry's Chemical Engineers Handbook and observations made
while visiting sodium carbonate plants during source tests in 1979.
Overhead was assumed to be 80 percent of maintenance labor, operating
labor, and supervision. Property tax, insurance, and administration are
45
reported in a publication in Control Technology News for pollution
control equipment. These factors were assumed to apply across the board
for all process equipment.
Annualized capital costs were computed using a compound interest rate
of 12% and an equipment service life of 30 years.
Increased costs for pollution control equipment for meeting Alter-
native 2 over Alternative 1 represent about 4 to 20 percent of the total
installed capital cost and about 3 to 7 percent of the total annualized
cost of the individual uncontrolled facilities. The increased capital costs
3-73
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TABLE 8-52. ENERGY COSTS'
Item
Electricity
Natural Gas
Steam
Coal
Unit Cost
Metric Units
$.0487 kwh
$.00213/106 J
$12.57/103 kg.
$.0004467 TO6 0
English Units
($2.25/106 Btu)
($5.70/103 Ib.)
($. 47/1 O6 Btu)
Cost data are in terms of the mid-1979 value of money.
8-74
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for pollution control represent less than 0.5 percent of the capital cost
of a new sodium carbonate plant producing 907,000 Mg/yr (1 million TRY).
8.2.3 Modified/Reconstructed Facilities
As noted in Chapter 5, few modifications or reconstructions are anti-
cipated for the sodium carbonate industry. Thus, the costs of control
systems for modified/reconstructed facilities will have a minimal impact on
the sodium carbonate industry.
However, if a modification or reconstruction were to occur, the cost
for installing a control system in an existing plant that has been modified
or reconstructed is generally greater than the cost of installing the
control system in a new facility with the same exhaust gas parameters
because special design modifications are often required.
Configuration .of equipment in the existing plant governs the location
of the control system. Depending on process or stack location, long
ducting runs from ground level to the control device and to the stack may
be required. The requirement for additional ducting can vary considerably,
depending on plant configuration.
If space within the plant is tight, it may be necessary to install
the control equipment on the roof of a process building, thus requiring
the addition of structural steel support. Roof top installation would
increase costs for installation of the control system.
Other cost components that may be increased because of space restric-
tions and plant configuration are contractor's fees and engineering fees.
These fees vary from place to place and job to job depending on the diffi-
culty of the job, the risks involved, and current economic conditions.
Estimating this additional installation cost or retrofit penalty is
difficult because of these plant-specific factors and additional engineering
requirements. However, the incremental costs to meet NSPS over the costs for
retrofitting to meet state standards would be similar to the incremental costs
for new plants, as presented in Section 8.2.2.
8-75
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8.3 OTHER COST CONSIDERATIONS
8.3.1 Costs Imposed by Water Pollution and Solid Waste Disposal
Regulations
Costs of compliance with water pollution and solid waste disposal
regulations do not currently have a strong impact on sodium carbonate
plants. Water and solid wastes in sodium carbonate plants are generally
discharged to tailings ponds, from which waste water evaporates. No waste
water is discharged into surface waters, and ground water in the area of
the sodium carbonate plants is of very poor quality.
8.3.2 Costs Associated with MSHA Compliance
Sodium carbonate plants are under the jurisdiction of the Mine Safety
and Health Administration (MSHA) and not the Occupational Safety and
Health Administration (OSHA). MSHA regulations require training and
education in safety and health and also deal with areas such as hazard
abatement, nuisance dust, and noise. The sodium carbonate industry has no
special problems requiring special MSHA regulations.
8.3.3 Compliance Testing (Air) Requirements
Compliance testing requirements for sodium carbonate plants would not
be excessive. For a single processing train, 2 or 3 test sites would be
required. Standard EPA test methods for particulates (such as Method 5)
would be used. Lengthy test runs would not be required.
8.3.4 Regulatory Agency Manpower Requirements
Future sodium carbonate plants are expected to be located in California
and Wyoming. Four plants are currently located in Wyoming, (with an
additional new plant planned) and two in California. Compliance tests
that would be required for sodium carbonate plants would be relatively
simple. Thus, regulatory agency manpower requirements should not be
excessive.
8-76
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8.4 ECONOMIC IMPACT ASSESSMENT
8.4.1 Introduction and Summary
8.4.1.1 Introduction. This section assesses the economic impact
of the alternative regulatory options on the Sodium Carbonate (soda ash)
industry. Economic profile information on the industry presented in Section
8.1 is a principal input to this assessment. The impact on individual new
sources will be assessed by using model plants that represent a new source
(two trains) or an expansion of an existing plant (one train). Various
financial analysis techniques are applied to the model plants to determine
potential impacts on affordability and capital availability. These findings
are assessed, based on the industry profile, to determine the industry-wide
impacts that will be presented in Section 8.5.
As noted in previous chapters the facilities of interest are the
^calcining, bleaching, and drying operations of natural soda ash production.
There is currently only one remaining plant that uses a synthetic production
process and no new synthetic production plants are projected to be built.
Therefore, controls for a synthetic plant are not within the scope of this
study. The model plants use one of two primary production processes, either
the monohydrate process or the direct carbonation process. Within the
monohydrate process there is an option to use a rotary steam tube dryer or a
fluid bed steam tube dryer. Hence, there are three model plant processes;
monohydrate (rotary dryer), monohydrate (fluid bed dryer), and direct car-
bonation. Each process has two plant sizes so there are a total of six model
plants. The monohydrate process is employed in producing soda ash from trona
ore, and the direct carbonation process is employed in producing soda ash
from brine.
8.4.1.2 Summary. A return on assets (ROA) analysis for the model plants
demonstrates that the addition of the most stringent regulatory option is
unlikely to have a significant profitability impact on the ROA for a soda ash
plant.
The soda ash industry exhibits inelastic demand. Therefore it is
likely that the cost of control will be passed-through to customers.
Such a complete pass-through to customers will raise the price of soda ash by
1 percent for the model plant with the highest control costs. In the
unlikely situation that the control cost must be absorbed by the producers,
the present profit margins are such that the profit reduction is unlikely
to have a major impact on ROA.
8-77
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The cost of control will add at most .5 percent to the total initial
investment required for a new monohydrate or direct carbonation model plant.
The additional .5 percent will not restrict capital availability for the
new plant.
The cost of control will add at most 7 percent to the total investment
for the facilities of interest, exclusive of other facilities, required for
an expansion of an existing monohydrate or direct carbonation plant. The
additional 7 percent will not restrict capital availability for a model plant
expansion.
Overall, the cost of control is unlikely to have a significant economic
impact on the new plant or an expansion to an existing plant.
8.4.2 Ownership, Location, and Concentration Characteristics.
Five large publicly held corporations each with from three to six
business segments own the eight soda ash plants in the United States. The
various business segments may or may not be related to soda ash, and soda
ash may be only one of several chemicals within a business segment. Some of
these corporations are significant users of the soda ash they produce. The
contribution to sales from soda ash ranges from approximately 1 percent to 7
percent of total sales in these corporations.
With the exception of the synthetic plant in New York the remaining
plants are located in Wyoming and California.
8.4.3 Supply
In general terms the supply and demand relationship in the soda ash
industry is stable. Production has grown at an average historical rate of 2
percent per year from 1967 to 1977. Production is projected to continue
growing by 2-3 percent per year through 1985.47
In recent years there has been a sharp changeover from the production
of synthetic to natural soda ash. Most of the former synthetic capacity
is now closed and there has been a major expansion of natural capacity.
In spite of the relatively short time involved and the magnitude of the
changes in capacity, the expansion of capacity to produce natural soda
ash has progressed in an orderly manner and has not caused disruptions
in the market. The expansion of natural production has effectively offset
the loss of synthetic production and met normal growth in demand, but
3-78
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at the same time has not resulted in excessive expansion of capacity leading
to an over supply situation. This is evidenced by a 92 percent industry capacity
utilization rate, and rising prices, which also suggest that new capacity will be
required to meet growth projections.
Figure 8-3 illustrates this stability. The bottom two sections of
the graph illustrate the extent of the change from the snythetic production
process to the natural production process that has occurred over an eleven
year span. As noted in Section 8.1 soda ash produced by the synthetic process
has declined from 73.7 percent of total soda ash production in 1967 to 15.7
percent in 1978. At the same time, the production of soda ash from the
natural process has increased in inverse proportion.
The top section of the graph illustrates that while the underlying
changes in the production process were taking place, the growth in the
total production of soda ash continued its historical pattern and was not
significantly disrupted.
8.4.3.1 Substitutes. Substitutes can influence the economics of a
given product by presenting an alternative source of supply to meet demand.
The possibility of substitution is one of a number of market factors that
act to check the price increases of a given product.
Caustic soda has historically been the only major substitute for soda
ash. Caustic soda and soda ash share some common markets which represent
roughly 40 percent of soda ash's end uses, primarily the chemicals market and
the pulp and paper market. As noted in Section 8.1.2 from a former price
advantage in favor of caustic soda, the prices of caustic soda have recently
risen so now neither caustic soda nor soda ash has a distinct price advantage.
Therefore, caustic soda is not currently as competitive as a substitute for
soda ash as in past years.
8.4.4 Demand.
The industry exhibits inelastic demand over an appreciable price range.
The weighted average price (both synthetic and natural) has risen by 139
percent over the past 11 years.48 There is no evidence of a significant
buildup of inventory in this industry nor is there a significant import market.
Therefore production can be considered equivalent to demand in this case.
Figure 8-4 illustrates the inelastic demand for soda ash which is
caused by several factors. First, the only significant substitute
8-79
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Figure 8-3. STABILITY OF TOTAL PRODUCTION OF SODA ASH
1967 = 100
Co
i
CO
o
O)
C
O)
u
OJ
Q.
130 -i
120 .
90 _
80
70
60
50
40
30
20
10
0
'67
Cumulative % growth in total production
natural
procuction as
a %
of tctal |
reduction
synthetic production as a % of total production
'68
i
'69
I
'70
I
'71
I
'72
Years
F
'73
i
'74
i
'75
'76
'77
'78
-------
Figure 8-4. RELATIONSHIP BETWEEN PRICE AND PRODUCTION
Soda Ash Price Index from 1967 = TOO
Soda Ash Production Index 1967 = 100
c
o
240
230
220
210
200
190 -
x 180
0)
•o
c
I— i
-------
(caustic soda) for soda ash has been experiencing price increases. The price
increases for caustic soda reduce the pressure to hold down price increases
for soda ash. Second, there is virtually no potential competition from
foreign imports of soda ash since foreign soda ash is produced using the
synthetic process which is considerably more expensive than the natural
process. Third, the total demand for the end products that contain soda ash
has been characterized by slow stable growth of approximately 2 percent per
year.47 As noted in Section 8.1.1 the relative position of the end use
industries for soda ash has historically been stable. Fourth, the cost of
soda ash represents a small portion of the total price of its end products.
Therefore, a small increase in the price of soda ash would require a substan-
tially lesser offsetting percent price increase in the end product and would
have little or no impact on demand for the end product. For example, the
glass industry consumes approximately 50 percent of the production of soda
ash. Within the various segments of the glass industry (flat glass, glass
containers, pressed & blown glass, etc.) the value of soda ash as a percentage
of the total value of the end product is highest for the glass containers
segment, 17.81 percent.49 Therefore if the price of soda ash increases by
1 percent, then the amount that the price of glass containers must rise in
order to offset a 1 percent price increase in soda ash is 1 percent x 17.81
percent, or .1781 percent.
In the glass industry segment of the soda ash markets the potential
for competition from plastic exists. Plastic has made some inroads in
the demand for soda ash but two factors both related to petroleum prices
tend to support soda ash demand. As petroleum prices continue to rise the
price of plastic also rises, and,as petroleum prices rise the demand for
fiberglass insulation (which contains soda ash) increases as homeowners
attempt to conserve energy.
8.4.4.1 Exports. Previous sections have noted the following points
which are germane with respect to a discussion of exports.
There is substantial world-wide demand for soda ash with the United
States being an exporter of sc a ash. Over the past ten years the export
market has grown from approximately 4.5 percent to 9 percent of U.S. pro-
duction.50 With the exception of a relatively small trona deposit in
8-82
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Africa, the rest of the world produces soda ash using the Solvay process.
The Solvay or synthetic process involves large amounts of energy and hence
high energy costs and poses a considerable water pollution problem. The
energy costs and/or the water pollution problem present the possibility
that foreign synthetic production plants may close prematurely or older
plants may not be replaced. Therefore the most likely replacement source of
supply would be the U.S. with the associated economic benefits to the U.S.
of increased export demand for soda ash, and an increased number of new
sources. However, foreign closures do not appear imminent during the next
five years.
8.4.5 Methodology
This section describes the methodology used to measure the economic
impact of the cost of control on the soda ash industry. The principal
economic impact which is assessed is the effect of incremental costs of
control on the profitability of new grassroots plants and expansions of
existing plants.
In the analysis, each new model soda ash plant is evaluated as if it
stands alone, i.e., the firm is not associated with any other business activity
nor is it associated with any larger parent company. This assumption has the
effect of isolating the control cost from any assistance from other business
activities or firms.
Since both the California and Wyoming state implementation plans
(SIP) contain particulate emission control standards, any new plant would
have to meet SIP standards even in the absence of an NSPS. Therefore,
incremental control costs are the control costs over and above those baseline
costs required to meet the SIP standards.
Economic impact is evaluated on a model plant of 1,000,000 tons per
year capacity whose description is based on representative production and
financial characteristics of a new or expanded soda ash plant. Results
can readily be extrapolated to smaller and larger plants because capacity
is attained by employing several production "trains", i.e. a 1,000,000
*
ton plant employs two 500,000 TRY trains.
The primary analytical technique employed in determining the impact
of control costs on the affordability of a soda ash plant is return on
assets (ROA) which compares net profit to the size of the asset base which is
8-83
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required to generate that profit. For example, a $10 profit earned on $100 of
assets equals 1:10, or a 10 percent ROA.
Projecting the actual level of ROA without controls is not a major
objective of this analysis. The issue of concern for this analysis is
whether or not the change that occurs in ROA is such that a capital investment
which would otherwise be accepted will now be rejected as a result of the
addition of control costs. The actual level of ROA will vary from case to
case and will be influenced by a number of factors such as the age of the
assets. In this analysis, the actual level of ROA without control, is
substantially below a level that might be termed "normal" for the industry
for several reasons. The 85 percent capacity utilization rate used to
estimate control costs in Section 8.2 and therefore also used in the model
plant economic analysis is conservative. As mentioned in Section 8.1 the
historic capacity utilization rate for the natural soda ash industry has been
92 percent. Using an 85 percent capacity utilization rate acts to reduce
profit and lower ROA. The initial capital investment in a soda ash facility.
typically includes mine capacity for future expansion. This causes the ROA to
be low in the early years of plant operation prior to such expansion. As
capacity is expanded, a significant portion of the investment cost associated
with expansion has been made previously at the time of the initial investment
so that to gain additional units of capacity requires a proportionately
smaller unit investment cost, which raises ROA. The 50 percent tax rate
assumed in this analysis is higher than typical for the soda ash industry for
several reasons. The 14 percent depletion allowance for trona is a significant
contributor to a lower effective tax rate. Data on effective tax rates on
trona are not separately available, but are combined in divisional product
information. However, all indications suggest that these rates may be
between 25 and 40 percent. Also, the 10 percent investment tax credit
available on the plant facilities has not been included in this analysis
which would further reduce effective tax rates. These conservative assumptions
result in significantly understating the probable net profits in this
industry. The purpose of this analysis is to determine the difference in ROA
due to control investments. The conclusions relative to the impact of
controls on the profitability of this industry are not affected by the
conservative baseline assumptions.
8-84
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The procedure employed is first to calculate the baseline ROA that
would be earned without controls. Next, the most costly controls are added
and the ROA is recalculated. The difference between the above two calculations
represents the impact of the most costly controls on profitability as measured
by ROA.
8.4.6 Profitability Analysis-Return on Assets
Table 8-53 shows the return on assets (ROA) analysis for a new 1,000,000
TRY plant without controls, a new plant with controls, and the difference in
ROA between the two. All cost figures are in mid-1979 dollars.
In addition to the controls that are the subject of this project, new
sources in the soda ash industry will also be regulated by the controls
required for non-metallic mineral processing plants. The non-metallic
mineral controls have not been finalized at this time. However, as they
apply to the soda ash industry, the non-metallic mineral controls are expected
to involve costs of approximately .1 percent of the sales price per ton of
soda ash.
The numerator in the ROA analysis is net earnings after tax, taken as
8 percent of revenue. This is based on the historical pre-tax profit in
the industry. For the five companies in the soda ash industry the average
after tax profit on revenue for the years 1978, 1977, and 1976 for the
business segment that includes soda ash was 8.4 percent.46 This assumes
taxes and interest represent a combined total rate of 50 percent. The 8.4
percent average margin has been rounded to 8.0 percent to be conservative
and to adjust for the controls for non-metallic minerals. The price of dense
soda ash sold in bulk form is $66 per ton.51*52. As discussed in Section
8.1, annual production is 85 percent of 1,000,000 tons of capacity, or
850,000 tons per year. Therefore, the numerator is $66/ton x 850,000
tons/year x 8 percent = $4,488,000.
The denominator is the asset base. $280,000,000 represents an approxima-
tion of the total assets required for a new facility including associated
mine or well facilities with 1,000,000 tons capacity.53' 54» 55> 56
#
Each year of the project life the assets would be depreciated and would
result in a progressively smaller asset base supporting an essentially
constant amount of total income. This action would cause a low ROA during
the early years of the project and a high ROA during the late years. If
straight line depreciation with no residual value is assumed this effect
can be considered by multiplying the original committed assets by 1/2.
8-85
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TABLE 8-53. CHANGE IN RETURN ON ASSETS
FOR A 1,000,000 TRY PLANT ASSUMING NO COST PASS-THROUGH
($000's)
ROA Without Control
Net Earnings After Tax
Average Total Assets
4.488
140,000
3.2%
ROA With Control
(Net Earnings After Tax) - (Control Cost After Tax)
(Avg. Total Assets) + (Avg. Control Investment)
4,488 - 338
140,000 + 663
4.150
T40.663
3.0%
Change In ROA = (ROA without control) - (ROA with control)
= 3.2 - 3.0 = .2
% Change in ROA
.2
= 6%
8-86
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In the model plant analysis the asset base of $280,000,000 is multiplied by
1/2 to determine an average asset value over the project life of $140,000,000.
The change in ROA that is caused by the addition of controls can be
derived by reducing net-earnings after tax by the additional after tax
expense (a 50 percent tax rate is assumed) of controls, which is $338,000
as derived from Tables 8-33 to 8-45. The control cost for a monohydrate
plant with a fluid bed steam tube dryer is used as a worst case since this
model plant involves the most costly controls. Next, the total assets
must be increased by the average additional investment for controls as
shown in Table 8-29, $1,326,000 x 1/2 = $663,000.
The soda ash producers can make one of three reasonable price responses
to the additional control costs: Prices can be raised by an amount sufficient
to completely pass-through the additional costs. Prices can be raised by an
amount to partially pass-through the additional costs, or prices can remain
the same and the additional costs can be completely absorbed by the producers.
The most probable response by the producers is to raise prices sufficiently
to completely pass-through the additional control costs. Several principal
factors suggest this response as the most probable. First, demand for soda
ash is inelastic. Second, three of the current five members of the industry
are projected to make expansions which will be "new sources", therefore a
significant portion of the soda ash industry will be directly affected.
Third, the amount by which the price must be increased in order to completely
pass-through the control costs is 1 percent, or approximately 67g must be
added to a $66 per ton sales price. This 67tf price increase can be compared
to price increases of $6 per ton in January of 1979 and $5 per ton in April
of 1979.
From the producer's point of view the worst case would be complete
absorption of the control costs. In this case the producer's pre-tax
profit margin would be reduced by the above mentioned 67£ per ton. The
results of the return on assets analysis show that complete absorption
of the control costs changes the after tax return on assets by 6 percent
from 3.2 percent to 3.0 percent.
8-87
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This 6 percent change in ROA is not likely to significantly alter the invest-
ment decision for a company which would otherwise make an investment. Also, the
impact on ROA of adding controls is reduced significantly as the level of ROA is
increased to what might be termed a "normal" level.
8.4.7 Capital Availability for Control Systems
The necessary capital is likely to be available to companies for the purchase
of control equipment.
The total capital required for control of a new 1,000,000 ton monohydrate
plant with a fluid bed steam tube dryer would add $1,326,000 to an initial investmei
of $280,000,000, a .5 percent increase. The total capital required for control of a
1,000,000 ton monohydrate plant with a rotary steam tube dryer, or a direct
carbonation plant would require an additional initial investment of .4 percent and
.2 percent, respectively. This increase in the initial investment is not likely to
seriously alter the capital availability situation for a new plant which otherwise
can obtain the necessary capital.
The total capital required for control of an expansion of an existing mono-
hydrate model plant with a fluid bed steam tube dryer would add $663,000 to the
additional investment of $9,512,000 required for the facilities of interest or 7
percent. The total capital required for control of an expansion of an existing
monohydrate plant with a rotary steam tube dryer, or an expansion of a direct
carbonation plant would require an additional investment of 5.7 percent and 3.5
percent respectively. It should be noted that the total investment cost for the
full added facility would be greater than the estimated costs for the facilities of
interest since the facilities of interest are only those processes which require
direct controls such as the calcining operations, the rotary steam tube dryer,
bleacher, etc. $9,512,000 does not include other equipment required for increased
capacity that does not require direct control. Therefore, the 7, 5.7- and 3.5
percent increases are higher than would be actually encountered. Such increases in
the initial investment are not likely to seriously alter the capital availability
situation for an expansion which could otherwise be financed.
-------
8.5 SOCIO-ECONOMIC IMPACT ASSESSMENT
The purpose of Section 8.5 is to address those tests of maroeconomic
impact as presented in Executive Order 12044 and more generally to assess any
other significant macroeconomic impacts that may result from the addition of
controls.
The economic impact assessment is only concerned with the costs
or negative impacts of the controls. The controls will also result in
benefits or positive impacts such as cleaner air and improved health for the
population, potential increases in worker productivity, increased business
for the pollution control manufacturing industry, and so forth. However, the
control benefits will not be discussed here.
EXECUTIVE ORDER 12044
Executive Order 12044 provides several criteria for a determination
of major economic impact. Those criteria 57 an(j findings are:
Criterion:
1. Additional annualized costs of compliance that, including capital charges
(interest and depreciation), will total $100 million (i) within any one
of the first five years of implementation (normally in the fifth year for
NSPS), or (ii) if applicable, within any calendar year up to the date by
which the law requires attainment of the relevant pollution standard.
Fi ndi ngs:
The controls are projected to apply to three expansions of 500,000 tons
each; one monohydrate (rotary dryer), one monohydrate (fluid bed
dryer), and one direct carbonat ion. This will result in respective
fifth year annualized costs of $187,000, $338,000, and $193,000 for
a total of $718,000.
Criterion:
2. Total additional cost of production of any major industry product or
service will exceed 5 percent of the selling price of the product.
*
Fi ndi ngs:
The controls will add a maximum of 1 percent to the selling price of the
product.
-------
Criterion:
3. Net national energy consumption will increase by the equivalent of
25,000 barrels of oil per day.
Findings:
The increase in energy consumption caused by the controls will be
equivalent to approximately 55 barrels of oil per day.
Criterion:
4. Additional annual demand will increase or annual supply will decrease
by more than 3 percent for any of the following materials by the attainment
date, if applicable, or within five years of implementation: plate
steel, tubular steel, stainless steel, scrap steel, aluminum, copper,
manganese, magnesium, zinc, ethylene glycol, liquified petroleum gasses,
ammonia, urea, plastics, synthetic rubber, or pulp.
Findings:
Soda ash is not included in the materials mentioned above. In spite
of this, the controls will result in no perceptible change in demand or
supply since the control costs are not expected to inhibit investment in
new or expanded plants and since the price inelasticity for soda ash is
such that a control cost pass-through is not expected to reduce demand.
Additionally, both the small dollar cost of the controls and the inherent
economics of the industry, such as; its geographical concentration, the size
of the industry members, the stability of supply and demand, the lack of
significant foreign natural deposits, et al., preclude the possibility of
significant macroeconomic impacts either on a regional or on a national
basis. The control costs will not aggravate national inflation, disrupt
regional or national employment patterns, or change the U.S. Balance of
Payments position
8-90
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8.6 REFERENCES
1. Foster, Russell J., "Sodium Carbonate", Mineral Commodity Summaries
1979, pp. 148-149.
2. Klingman, Charles L., "Soda Ash (Sodium Carbonate), Sodium Sulfate,
and Sodium", Mineral Facts and Problems, 1975 ed., p. 1020.
3. Staff of the U.S. Bureau of Mines, "Sodium and Sodium Compounds",
Bureau of Mines Minerals Yearbook, yearly editions 1952, 1962, 1969,
1972, and 1976.
4. Telecon, Alan Secrest, Radian Corp. with Jack Rourke, Allied Chemical
Co., Syracuse Plant, March 27, 1979.
5. Telecon, Alan Secrest, Radian Corp., with Sam Berger, U.S. Department
of Commerce, March 27, 1979.
6. Reference 3, 1975 edition.
7. Staff of the U.S. Bureau of Mines, Division of Nonmetallic Minerals,
"Sodium Compounds Monthly", Mineral Industry Surveys, Prepared
February 8, 1979.
8. Telecon, Alan Secrest, Radian Corp., with Russell Foster, U.S. Bureau
of Mines, March 27, 1979.
9. References, Yearly editions 1967 through 1976.
TO. Staff of the U.S. Bureau of Mines, Division of Nonmetallic Minerals,
"Sodium Compounds in 1977", Mineral Industry Surveys, Advance Annual
Summary.
11. Parkinson, Gerald, "Kerr-McGee expands soda ash output nine-fold from
Searles Lake brines", E/MJ, October 1977, p. 71.
12. Stauffer Chemical Co., Emission Inventory, 1977.
13. Reference 2, p. 1025
14. Starr, Homer C., "In alkali battle, five bet on the underdog",
Chemical Week, November 3, 1976.
15. Telecon, Alan Secrest, Radian Corp., with Russell Foster, U.S. Bureau
of Mines, March 23, 1979.
16. Staff, Executive Office of the President Council on Wage and Price
Stability, A Study of Chlorine, Caustic Soda Prices, Staff Report
August 1976.
8-91
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17. Reference 2, p. 1023.
18. Telecon. Secrest, A., Radian Corporation with Barry Klein, Department
of the Interior, Division of Economic Analysis, May 2, 1979. Normali-
zation of prices to correct for inflation.
19. Staff of the U.S. Bureau of Census, "Inorganic Chemicals", Current
Industrial Survey, Annual Summaries, M28A(71)-14, M28A(75)-14,
M28A(77)-14.
20. Staff of the U.S. Bureau of Mines, Division of Nonmentallic Minerals,
"Sodium Compounds in 1978", Mineral Industry Surveys, Annual Preliminary.
21. Reference 3, yearly editions 1974 through 1976.
22. Trip Report. FMC Corporation - Industrial Chemical Division, Green
River, Wyoming. February 21, 1979. Prepared by T.G. Sipes, Radian
Corporation.
23. Blythe, G.M., Sawyer, J.W., Trede, K.N., "Screening Study to Determine
Need for Standards of Performance for the Sodium Carbonate Industry",
Radian Corporation, DCN 78-200-187-34-08, p.11.
24. Reference 2, p. 1021.
25. Reference 23, p. 35.
26. Guthrie, Kenneth M. Process Plant Estimating, Evaluation and Control.
Solana Beach, California. Craftsman Book Company 1974.
27. Kinkley, M.L. and R.B. Neveril. Capital and Operating Costs of Selected
Air Pollution Control Systems. EPA-450/3-76-014. GARD, Inc., Niles,
Illinois. May, 1976.
28. Neveril, R.B., J.V. Price, and K.L. Engdahl. "Capital and Operating
Costs of Selected Air Pollution Control Systems - V". Journal of the A1r
Pollution Control Association, Vol. 28, No. 12, December, 1978, pp. 1253-1256.
29. Telecon. Sipes, T.G., Radian Corporation with Jim Miller, Buell
Envirotech, July 19, 1979. Cost estimates for cyclones.
30. Telecon. Sipes, T.G., Radian Corporation with Peter Gunnell,
Buell-Envirotech, July 12, 1979 and July 18, 1979. Cost estimates
for electrostatic precipitators.
31. Telecon. Sipes, T.G., Radian Corporation with Mike Zolandz, Research
Cottrell, July 18, 1979. Cost estimates for electrostatic
precipitators.
8-92
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32. Telecon. Sipes, T.G., Radian Corporation with Don Frendberg, United
McGill, July 27, 1979. Cost estimates for electrostatic precipitators.
33. Telecon. Sipes. T.G., Radian Corporation with Bill Rudy, Ducon,
July 19, 1979. Cost estimates for venturi scrubbers.
34. Telecon. Sipes, T.G., Radian Corporation with Mike Heuman, Fisher
Klosterman, July 19, 1979. Cost estimates for venturi scrubbers.
35. Reference 27, p. 4-2.
36. Telecon. Secrest, A., Radian Corporation with Bill Rudy, Ducon,
November 13, 1979. Cost estimates for venturi scrubbers.
37- Reference 27, pp. 4-4, 4-5, 4-6.
38. Telecon. Sipes, T.G., Radian Corporation with a representative of a
dryer vendor, July 24, 1979. Cost estimates for dryers and calciners.
39. Perry, R.H., and C.H. Chilton, Chemical Engineers' Handbook. 5th ed.
New York, McGraw Hill Book Company, copyright 1973, pp. 20-40, and
20-41.
40. Reference 27, pp. 4-40, 4-71, and 4-72.
41. Reference 28, p. 1254.
42. Reference 38, pp. 10-40 and 20-36.
43. Letter from L.V. Lee, Dorr-Oliver, Incorporated, to D.T. Smith, Radian
Corporation. August 1, 1979. Cost estimate for potash dryer.
44. Reference 38, pp. 20-40 and 28-42.
45. Reference 28, p. 1255.
46. Allied Chemical Corporation 1978 Annual Report, p. 43. FMC Corporation
1978 Annual Report, p. 4, 35. Kerr-McGee Corporation 1978 Annual Report,
p. 36. Stauffer Chemical Company 1978 Annual Report, p.- 26, 27.
Texasgulf, Inc. 1978 Annual Report, p. 34.
47. Section 8.1, p, 8-14.
48. Reference 47, p. 8-6, 8-9,
49. 1972 Census of Manufactures, U.S, Department of Commerce, Bureau of
the Census, 32A-20. Glass Products.
50. Reference 47, p. 8-18.
8-93
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51. Texasgulf, Inc., 1978 Annual Report, p. 6.
52. Chemical Marketing Reporter. August 6, 1979, p. 36.
53. Parkinson, Gerald. Kerr-McGee expands soda ash output nine-fold from
Searles Lake brines. Engineering & Mining Journal, pp. 71-75,
October 1977.
54. Telecon. Kostick, Dennis S. U.S. Bureau of Mines with John W. Gracey,
JACA Corporation. August 24, 1979. Investment cost information for
soda ash facility.
55. Telecon. Sam Berger, U.S. Bureau of Census with John W. Gracey.
JACA Corporation. August 24, 1979. Investment cost information for
soda ash facility.
56. Letter from David R. Delling, Tenneco Oil, to Thomas V. Costello,
JACA Corporation, October 3, 1979. Response to request for investment
cost information for soda ash facility.
57. Manual for the Preparation of NSPS Economic Impact Statements.
Economic Analysis Branch. Strategies and Air Standards Division,
U.S. Environmental Protection Agency, Research Triangle Park, North
Carolina 27711. p. 8.
8-94
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9. RATIONALE FOR THE PROPOSED STANDARD
9.1 SELECTION OF SOURCE FOR CONTROL
The sodium carbonate industry is one of a number of industries
which the Administrator has determined contribute significantly to air
pollution (40 CFR 60.16, 44 FR 49222, August 21, 1979). These industries
are included in a priority list of sources for which new source perfor-
mance standards are to be promulgated. This priority list ranks the
emission sources on a nationwide basis in terms of quantities of emissions
from the source category, the mobility and competitive nature of each
source category, and the extent to which each pollutant endangers health
and welfare. The sodium carbonate industry ranks 35th out of 59 source
categories on this priority list.
Sodium carbonate can be produced by either natural or synthetic
processes. In natural processes, sodium carbonate is produced from
naturally occurring ores or brines which contain sodium sesquicarbonate,
sodium bicarbonate, or sodium carbonate. In synthetic processes, sodium
carbonate is produced from sodium chloride and limestone.
The overall growth rate in sodium carbonate production in recent
years has been somewhat slow but relatively stable. The Bureau of Mines
has projected an annual growth rate of 3 percent per year for the period
from 1976 through 1985. Production of sodium carbonate by natural pro-
cesses has grown more rapidly than this in the last ten years, but much
of this growth has been due to replacement of synthetic sodium carbonate
production capacity. Since only one synthetic sodium carbonate plant
now remains in operation, future growth in natural sodium carbonate
production will not be as rapid as it has been over the past ten years.
Standards are being proposed only for natural process sodium carbonate
plants because no growth is expected for synthetic sodium carbonate
plants. Synthetic sodium carbonate production in the United States has
9-1
-------
dropped from 4.4 million Mg/yr in 1967 to 1.1 million Mg/yr in 1978,
while natural production has grown from 1.6 million Mg/yr to 6.2 million
Mg/yr over the same period. Over the past 12 years, nine synthetic
sodium carbonate plants were shut down. Only one synthetic sodium
carbonate plant is now in operation in the United States.
This decline in synthetic sodium carbonate production has resulted
largely from rising energy costs and increasingly stringent water pollution
regulations. Production of sodium carbonate by synthetic processes
requires about twice as much energy as production by natural processes.
Natural process sodium carbonate plants discharge no waste water stream,
while synthetic processes discharge an aqueous waste stream containing
calcium chloride. Treatment of this waste stream is difficult and
expensive. With the exception of the northeast, the market demand for
sodium carbonate can now be supplied at the lowest overall production
and transportation cost by natural process plants in Wyoming and California,
9.2 SELECTION OF POLLUTANTS AND AFFECTED FACILITIES
9.2.1 Affected Facilities
Particulates are generated in sodium carbonate plants by various
processing operations. These operations include dissolving the mined
ore and drying and handling the final product. Facilities in natural
process sodium carbonate plants for which standards are proposed are
calciners, dryers (including predryers), and bleachers. These facilities
are all major sources of particulate emissions. Projected emissions
from each new facility in 1985 under present levels of control are
presented in Table 9-1.
Standards are not being proposed for other emission sources in
sodium carbonate plants. First, boilers for steam and power generation
in sodium carbonate plants are included within the scope of a program to
develop an industrial boiler NSPS. Next, many emission sources, including
crushers, grinding mills, screening operations, bucket elevators, conveyor
transfer points, bagging operations, storage bins, and fine product (20
9-2
-------
TABLE 9-1. PROJECTED EMISSIONS FROM NEW SODIUM CARBONATE PLANTS IN 1985
UNDER PRESENT LEVELS OF CONTROL3
Emission Source
Calciner
Dryer
Predryer
Bleacher
TOTAL
Number of Sources
2
3
2b
1
Emissions
Mg/yr
264
275
123
36.6
700
Tons/yr
290
303
136
40.2
768
Includes emissions from new facilities only;
facilities which commenced construction before
1980 are not included. Based on process weight regulation,
There are 2 predryers in a single processing train.
9-3
-------
mesh and smaller) loading are included within a program to develop NSPS
for generic sources in non-metallic mineral processing plants. Other
potential emission sources in sodium carbonate plants include stockpiling,
conveying, and windblown dusts. However, these are fugitive sources
common to many mineral industries rather than process sources, and a
specialized program would be required to identify and study them. For
these reasons, process emission sources rather than general fugitive
sources were emphasized in this standard development program for the
sodium carbonate industry.
Standards for dissolvers and dissolver-crystallizers are also not
proposed because they are not significant emission sources. Dissolvers
in plants built since about 1973 are currently controlled in order to
comply with State opacity regulations or to control internal dusting
problems. Emissions from dissolvers are small compared to the other
emission sources considered. Under current levels of control, dissolver
emissions contribute no more than 2.5 percent of the process emissions
from the sodium carbonate industry. Thus, a dissolver emission standard
is not proposed because it would have a very small impact on reducing
plant emissions. However, if dissolver gases are exhausted through the
calciner emission control device, the standard for particulate matter
for calciners would apply to the combined gas stream.
In some plants, the exhaust gas from the calciner is recycled to
carbonation towers for utilization of the carbon dioxide. Transfer of
the exhaust gas requires a fan which must be protected from damage that
would result from impaction by particulate matter in the gas stream.
For this reason, particulate emissions from calciners are reduced by gas
scrubbers before the gas is exhausted to carbonation towers. Emissions
are further reduced as the gas passes through the carbonation towers.
The remaining particulate emissions from these calciners will thus be
very low. Moreover, the us? of carbonation towers which utilize calciner
exhaust gases is not typical of the industry on a nationwide basis.
Thus, a standard is not proposed for these carbonation towers at this
time. However, these standards will be reevaluated during the four
9-4
-------
year review and standards for carbonation towers could be considered if
these circumstances are found to change.
9.2.2 Pollutants
All of the facilities for which standards are proposed are major
sources of particulate emissions. Small amounts of sulfur oxides and
organics are also emitted from direct-fired calciners, but source tests
have indicated that these emissions are very low compared to uncontrolled
particulate emissions. Sulfur dioxide emissions from a coal fired
calciner were measured to be less than 0.0076 kg/Mg (0.015 Ib/ton).
Organic emissions from calciners averaged approximately 30 ppm for
a coal-fired calciner and 150 to 2,000 ppm for a gas-fired calciner.
These emissions were measured by use of a gas chromatograph flame ionization
detector and are reported as methane. The actual organic species present
were not determined. The organic emissions are believed to result from
oil shale which is present in the trona ore, and probably consist of
high molecular weight compounds. The actual organic emissions would
thus be only a fraction of the reported values. For example, if the
organic species are mainly Cg, the emissions in ppm of Cg would be one-
sixth of the emissions reported as ppm of methane. In addition, no
control technology has been demonstrated in the sodium carbonate industry
for controlling organic emissions. Thus, standards are proposed only
for particulate emissions.
9.3 SELECTION OF THE BASIS OF THE PROPOSED STANDARDS
Particulate emissions from sodium carbonate plants can be effectively
controlled by conventional add-on particulate control techniques.
Source tests conducted at three sodium carbonate plants along with
industry data led to the selection of electrostatic precipitators as the
best system of emission reduction for calciners and bleachers and venturi
scrubbers as the best system for dryers and predryers.
Two alternatives were considered for regulating emissions from
sodium carbonate plants. These alternatives are defined in Chapter 6.
Under Alternative 1, facilities would be controlled to essentially the
same extent as required by the most stringent of existing SIP regulations.
9-5
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Alternative 2 would set lower emission limits for each individual facility
based on the best level of control demonstrated for the facility in the
sodium carbonate industry. The emission limits used to conduct the
impact analysis for the two alternatives are presented in Table 9-2.
Control techniques capable of achieving the emission limits that
would be required under Alternative 2 include electrostatic precipitators
(for calciners and bleachers) and venturi scrubbers (for dryers and
predryers). The emission levels corresponding to Alternative 2 have
been demonstrated using these techniques, but other techniques could
also potentially be used to meet these emission levels. In most cases
the same type of control technique would be used to meet Alternatives 1
and 2, but venturi scrubbers used to meet Alternative 2 would have
higher pressure drops and ESP's would have larger plate areas.
The environmental, energy, and economic impacts of Alternative 1
are based upon typical State Implementation Plan requirements. These
requirements establish a baseline for determining the incremental impacts
of the proposed standards. However, in Wyoming, where much of the new
plant growth is projected, baseline control requirements may be more
stringent than SIP controls. During new source review for best available
control technology (BACT), the State has recently required new plants to
meet emission limits which are almost equivalent to the proposed standards.
The potential effect of Wyoming's BACT policy was considered in the
analysis of impacts, which are summarized below.
Under Alternative 1, projected particulate emissions from new
sodium carbonate plants would reach 700 Mg/yr (768 TPY) by 1985. However,
when Wyoming BACT determinations are projected to apply to all new
plants in that State, estimated national particulate emissions from new
sodium carbonate plants are projected to reach 440 Mg/yr (490 TPY).
Under Alternative 2, projected emissions would be 315 Mg/yr (347 TPY) in
1985, which represents a 55 percent reduction in emissions over Alternative 1
(28 percent reduction assuming BACT has been applied to Wyoming plants).
9-6
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TABLE 9-2.
EMISSION LIMITS FOR THE REGULATORY ALTERNATIVES
AND THE PROPOSED STANDARD
Calciner
Dryer
Predryer
Bleacher
Alternative 1
(baseline)3
kg/mg
0.15
0.25C
0.08
0.06
Ib/ton
0.30
0.50
0.16
0.12
Alternative 2
(basis for standard)
kg/mg
0.1
0.04
0.04
0.02
i_ Ib/ton
0.2
0.08
0.08
0.04
Proposed
Standard b
kg/mg
0.11
0.045
0.045
0.03
Ib/ton
0.22
0.09
0.09
0.06
Based on process weight regulation.
The standard ultimately proposed is slightly less stringent than
Alternative 2 upon which the impact analysis was based.
cFor monohydrate process (Wyoming).
9-7
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No secondary environmental impacts would result from implementation
of either of the regulatory alternatives. Scrubber liquor effluents
and particulates recovered in the emission control systems are directly
recycled to the process. Thus, there are no liquid or solid waste
streams from the emission control equipment which are not contained.
The incremental increase in energy consumption in going from
Alternative 1 to Alternative 2 is small in comparison to the total
energy required by the process equipment. The largest incremental
increase is for the model plant with a fluid bed dryer controlled by a
cyclone/venturi scrubber. For this model plant, the increased energy
consumption in going from Alternative 1 to Alternative 2 is about 53 TJ
per year (5x10 Btu/yr). The energy increase in going from the BACT
level to Alternative 2 would be much less. Energy consumption for the
12
entire sodium carbonate plant is about 3700 TJ per year (3.5 x 10 Btu/yr).
Thus, a standard based on Alternative 2 would result in about a 1.4 percent
increase in the energy consumption of sodium carbonate plants, and would
have a minimal impact on national energy consumption.
Capital costs of about $2.2 to 5.5 million (depending on process
configuration) would be required for pollution control equipment to meet
Alternative 2 for a typical plant producing 454,000 Mg/yr (500,000 TRY)
sodium carbonate. These capital costs are about $240,000 to $690,000
greater than costs required to meet the Alternative 1 control level.
Incremental costs to meet the Alternative 2 level over the BACT level
would be less since costs to meet the BACT level would be higher than
the costs to meet Alternative 1. The total increase in capital cost for
all new, modified, or reconstructed plants in 1985 to meet Alternative 2
compared to Alternative 1 is $1.5 million.
The economic impact under Alternative 2 would be minimal. Costs of
compliance with the Alternative 2 control levels would result in a price
increase for sodium carbonate of one percent (about 66 cents per ton) or
less. This increase could be passed on to sodium carbonate consumers
without significantly affecting the industry. If the costs were to be
absorbed by the producers, the resulting profit reduction would be
unlikely to have a major impact on the producer's return on assets.
9-8
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Based on the reduction in national particulate emissions, the
absence of adverse secondary environmental impacts, the minimal energy
impacts, and the reasonable economic impact, Alternative 2 was chosen
over Alternative 1 as the basis for the proposed standard.
9.4 SELECTION OF THE FORMAT OF THE PROPOSED STANDARDS
Several different formats for the proposed standard were considered.
These included percent control, mass per unit time, mass per unit of
production, and concentration.
The percent control format provides a direct measurement of the
performance of the control equipment, but not of emissions. This
format would require more costly performance testing since inlet as well
as outlet measurements must be made and would also complicate the test
because inlet loadings are high and would be more difficult to measure.
This format has no overall advantages relative to alternative formats
which could be selected. For these reasons, the percent control format
was not selected.
A mass per unit time format (e.g., kg/hr) directly monitors the net
quantity of pollutants emitted. However, this format would not allow
for variations in unit size or production rate, and large facilities
operating at full production would be penalized relative to smaller
facilities or facilities operating at a reduced capacity. For this
reason, the mass per unit time format was not selected.
A mass per unit of production format also directly monitors the net
quantity of pollutants emitted, but also provides flexibility to allow
for variations in unit size, production rate, and process parameters
such as changes in air flow rates. Enforcement would be somewhat more
complicated than for a mass per unit time or concentration standard
since this format requires accurate determination of production rate.
However, enforcement would be simpler than for the percent control
format since inlet testing is not needed. This format would require
stricter percent control for facilities with higher inlet emission
rates.
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A concentration format may be somewhat easier to enforce than a
mass per unit of production format since production rate must be monitored
only to the extent necessary to ensure that the facility is operating
near full capacity during tests. Furthermore, vendors of emission
control equipment usually guarantee equipment performance in terms of
the pollutant concentration in the discharge gas stream. However, there
is also a potential for reducing the effectiveness of a concentration
standard by diluting the exhaust gases discharged to the atmosphere with
excess air, thus lowering the concentration of pollutants emitted but
not the total mass emitted. With direct fired facilities this problem
can usually be overcome by correcting the concentration measured in the
gas stream to a reference condition such as a specified oxygen or carbon
dioxide percentage in the gas stream. However, for steam heated dryers
and predryers it would not be possible to correct the concentration to
account for dilution by excess air.
The mass per unit of production format was selected as the most
suitable format for regulation of particulate emissions from sodium
carbonate plants because of its flexibility to allow for variations in
unit size, production rates, and air flow rate and its direct relationship
to the quantity of particulate emissions. These advantages outweigh the
disadvantages associated with the requirement for accurate determination
of process weight.
9.5 SELECTION OF EMISSION LIMITS
Facilities at three sodium carbonate plants were tested by EPA to
evaluate techniques used for controlling particulate emissions and to
quantify the emission control levels achieved. Results of these tests
are presented in Appendix C of the Background Information Document.
Emission limits for each facility were selected baseH on the demonstrated
performance. The proposed standard is based on Alternative 2 because
this results in decreased national particulate emissions and does not
impose unreasonable economic and environmental impacts.
Visible emission standards are also proposed for each individual
facility. These standards will help to ensure the proper operation and
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maintenance of the control equipment required to meet the mass emission
standards. These opacity standards are not intended to be more restrictive
than the mass emission standards, but merely to supplement them.
Because of differences in uncontrolled emission rates, gas flow
rates, and gas and particle characteristics, all emission points are not
controlled to the same emission level. Thus, separate emission limits
were set for calciners, bleachers, and dryers. The rationale for selecting
each of the emission limits is discussed below.
9.5.1 Calciners
The proposed emission limit for calciners is 0.11 kg/Mg dry feed
and 5 percent opacity. These limits are based on testing of a coal-
fired calciner. As shown by data in Chapter 3, coal-fired calciners
have higher gas flow rates and uncontrolled particulate rates than gas-
fired or steam tube calciners and thus represent the more difficult case
for emission control. No other factors were found which might affect
the relative control capabilities of an ESP on various types of calciners.
For example, calciners used in the different natural processes for
producing sodium carbonate generally have feeds with similar chemical
compositions. The chemical reactions which occur in the calciners are
also similar. Particle size analyses indicated no significant difference
in the particle size distribution of particulates emitted from various
calciners. These factors notwithstanding, data collected by EPA on gas-
fired calciners showed emissions exceeding the standard. However, the
units tested were older than the coal-fired calciner tested and, as
explained later, are not considered to be representative of well-
designed and operated control systems. Based on these findings, the
Administrator has concluded that any calciner used in natural process
sodium carbonate plants would be capable of meeting the proposed emission
level.
The average emission level determined in EPA tests of a coal-fired
calciner (including vented dissolver emissions) controlled by a cyclone/ESP
was 0.101 kg/Mg dry feed. The calciner was operated at greater than
90 percent of normal operating capacity during these tests. Tests
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conducted by industry have shown emission levels of 0.014, 0.031 and
0.072 kg/Mg for coal-fired calciners controlled by cyclones/ESP's.
Tests were also conducted by EPA on two gas-fired calciners.
Results of these tests are reported in Appendix C. These tests indicated
emission levels higher than the proposed standards. However, the control
equipment used at these calciners does not represent the best available
control technology. One of the calciners was controlled by a cyclone in
series with an electrostatic precipitator. During the source tests, the
first two fields of the four field ESP had low currents and voltages and
high spark rates compared to the other two fields. Thus, the test
results were not representative of what could be achieved with a properly
functioning ESP. The other gas-fired calciner tested was controlled by
a cyclone in series with a venturi scrubber. The venturi scrubber was
operated with an average pressure drop of about 85 cm (33 in.) of water.
At this pressure drop, a venturi scrubber will not achieve a removal
efficiency comparable to a four field ESP.
During these EPA source tests, the coal-fired calciner was observed
to have zero opacity most of the time. Emissions with zero opacity were
observed during 210 minutes of the total observation period of 330 minutes
(64 percent of the time). The maximum 6-minute average opacity level
observed during the remainder of the observation period was only 3 percent.
Sodium carbonate plant operating personnel have reported that an
intermittent bluish haze has been observed at the exhaust of a few
calciners. It is suspected that this haze could be caused by the light-
scattering properties of either fine organic aerosol droplets or particulate
matter. The blue haze was not visible during the opacity observations
made during the source tests and the opacity standards were not developed
with an adjustment for blue haze conditions. Thus, enforcement of the
opacity standard may not be appropriate during periods when the blue
haze is visible. Should tlrs haze cause a facility that is meeting the
mass emission standard to violate the opacity standard, the owner or
operator of such a calciner can petition the Administrator for a higher
opacity standard 11 certain conditions are met. The procedure is described
in 40 CFR 60.111(e).
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9.5.2 Dryers and Predryers
An emission limit of 0.045 kg/Mg dry product (0.09 Ib/ton) and
10 percent opacity is proposed for all types of dryers and predryers.
EPA test data indicate that rotary steam tube dryers, fluid bed steam
tube dryers, and rotary steam heated predryers can all meet the proposed
emission limit. No EPA test data were obtained on gas-fired dryers, but
gas-fired dryers are currently in use at only one sodium carbonate
plant, and new gas-fired dryers are not expected.
Average emission levels determined in EPA source tests were as
follows: 0.035 kg/Mg dry product for a rotary steam tube dryer controlled
by a venturi scrubber, 0.04 kg/Mg dry product for a fluid bed dryer
controlled by a cyclone/venturi scrubber, and 0.026 kg/Mg dry product
for a predryer controlled by a cyclone/venturi scrubber. During these
tests, the rotary steam tube dryer was operated at greater than 90 percent
of design capacity, and the fluid bed steam tube dryer was operated at
greater than 80 but less than 90 percent of normal operating capacity,
but calculations indicate that emissions from predryers at full capacity
would be 0.04 kg/Mg or less. (See Section 4.3.1.5).
During these EPA source tests the rotary steam tube dryer controlled
by a venturi scrubber was observed to have no visible emissions during a
total test time of 240 minutes. The rotary steam heated predryer was
also observed to have no visible emissions during a total test time of
360 minutes. The fluid bed dryer controlled by a cyclone/venturi scrubber
was observed to have no visible emissions greater than 10 percent opacity
during 120 minutes of-testing. All observed six-minute average opacities
were between 6 and 10 percent during the testing.
9.5.3 Bleachers
An emission limit of 0.03 kg/Mg dry feed and 5 percent opacity is
proposed for bleachers. The average emission level achieved in EPA
tests of a gas-fired bleacher controlled by a cyclone/ESP was 0.021
kg/Mg dry feed. During these EPA source tests the bleacher was observed
to have no visible emissions during a total test time of 360 minutes.
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The ESP tested by EPA was designed to treat emissions from three
bleachers in a single unit. Only two of the bleachers were in operation
during the source tests, and these bleachers were operated at greater
than 65 percent but less than 90 percent of design capacity. However,
the actual gas flow rate to the ESP during the source test was more than
90 percent of the design flow rate of the ESP. Since the efficiency of
an ESP depends upon the ratio of gas flow rate to plate area (according
to the Deutsch Anderson equation), the efficiency measured during these
source tests would be comparable to the efficiency that would be achieved
by a properly designed ESP at full capacity. Calculations indicate that
emissions from the bleachers at full capacity would be 0.026 kg/Mg or
less. (See Section 4.3.1.2.)
9.6 MODIFICATION/RECONSTRUCTION CONSIDERATIONS
EPA has reviewed the most likely changes that could occur in sodium
carbonate plants which could potentially be modifications. Each of
these changes would be made to increase production rate. These changes
would be (1) the installation of larger fans on a dryer and (2) the
modification to a combustion chamber of a calciner to allow increased
fuel consumption. Because a capital expenditure would be required and
an increase in particulate emissions would probably result, these would
probably be classified as modifications unless emissions were reduced to
their former levels.
If these changes occur on a calciner or dryer controlled by a
venturi scrubber, the scrubber pressure drop could be increased to
provide increased particulate removal so that the controlled particulate
emission rate would not increase. In this case the change would not
subject the facility to the NSPS.
These modifications are not expected to be common. They would
occur as part of an expansion where increased throughput would be possible
in the remainder of the processing train so that modifying the dryer or
calciner to allow increased throughput would increase the production
rate of the entire plant process operation. Because these modifications
are not expected to be common, and there are potential ways to compensate
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if they do occur, no special allowance or exemptions are made in the
standards for these modifications.
Another change which could potentially result in a modification is
the conversion of an existing gas or oil-fired calciner to coal firing.
Because converting the calciner to coal would require the calciner to be
derated to a lower production rate, the actual mass rate of emissions
from the calciner might not be increased in converting from gas to coal.
In that case, the change would not subject the calciner to NSPS. If,
however, the mass emission rate is increased above State emission standards,
improvements to the control device would be necessary. The additional
cost to bring emissions back to their former levels to prevent a modification
or at most comply with NSPS would be similar to the incremental cost for
compliance by new facilities.
9.7 SELECTION OF MONITORING REQUIREMENTS
Under Section 114(a) of the Clean Air Act, the Administrator may
require the owner or operator of any stationary emission source to
install, use, and maintain monitoring equipment or methods. EPA has
exercised this authority in the standards of performance for several
source categories by requiring the monitoring of pollutant emissions or
parameters that are indicators of pollutant emissions. The requirements
for continuous monitoring are necessary to determine if a control device
is being properly operated and maintained. It also aids in determining
when and if a performance test should be required.
Opacity monitoring systems are perhaps the most reasonable and
effective means of determining proper operation and maintenance of
cyclone/ESP and fabric filter emission control systems. Results of
opacity monitoring are not used to judge compliance with particulate
matter or opacity standards. However, if high opacity readings are
recorded, they would be justification for requiring performance tests
using Method 5 or Method 9. The opacity monitoring systems are substantially
less costly and more easily applied than periodic mass emissions tests
for particulate matter. Therefore, the use of a continuous opacity
monitoring system is proposed as a requirement.
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Entrained water droplets can prevent the accurate measurement of
opacity of the gas from wet scrubber systems. However, monitoring the
pressure drop across the scrubber and the fluid flow rate to the scrubber
are reasonable and effective means of determining proper operation and
maintenance of wet scrubbers. The scrubbing fluid flow rate may be
monitored by measuring either the scrubbing fluid supply pressure or by
measuring the scrubbing fluid supply flow rate directly. If the scrubbing
fluid supply pressure is monitored, the pressure sensor must be located
at a point where there are no valves between it and the scrubber. Thus,
at facilities with wet scrubber systems the proposed regulation would
require monitoring of scrubber pressure drop and scrubbing fluid flow
rate or supply pressure rather than monitoring of opacity.
Monitoring records must be maintained to be used in preparing
quarterly excess emission reports and so that they will be available for
review by enforcement personnel. Excess opacity measurements must be
reported or, when opacity monitoring is not applicable, any one hour
period for which the average scrubber pressure drop or scrubbing fluid
flow rate is less than 90 percent of the average level maintained during
the most recent performance test in which the facility demonstrated
compliance with the particulate standard must be reported.
9.8 SELECTION OF PERFORMANCE TEST METHODS
The use of EPA Reference Method 5, "Determination of Particulate
Emissions from Stationary Sources" (Appendix A, 40 CFR 60, Federal
Register, December 2, 1971) is required to determine compliance with the
mass standards for particulate matter emissions. Results of performance
tests using Method 5 conducted by EPA at three existing sodium carbonate
plants comprise a major portion of the data base used in the development
of the proposed standard. EPA Reference Method 5 has been shown to
provide a representative measurement of particulate matter emissions,
and would be used for deter lining compliance with the proposed standards.
Calculations applicable under Method 5 necessitate the use of data
obtained from three other EPA test methods conducted previous to the
performance of Method 5. Method 1, "Sample and Velocity Traverse for
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Stationary Sources" must be conducted in order to obtain representative
measurements of pollutant emissions. The average gas velocity in the
exhaust stack is measured by conducting Method 2, "Determination of
Stack Gas Velocity and Volumetric Flow Rate (Type S Pitot Tube)." The
analysis of gas composition is measured by conducting Method 3, "Gas
Analysis for Carbon Dioxide, Oxygen, Excess Air, and Dry Molecular
Weight." These three tests provide data necessary in Method 5 for
converting volumetric flow rate to mass flow rate. In addition, Method
4, "Determination of Moisture Content in Stack Gases" is suggested as a
better choice for determination of moisture content than the estimation
procedure under Method 5.
All observations for determining compliance with opacity standards
would be made in accordance with the procedures established in EPA
Method 9 for stack emissions. This method requires that a more representative
six-minute average of opacity observations rather than a single observation
be used to determine compliance.
Since the proposed standards are expressed as mass of emissions per
unit mass of feed to or product from a facility, it would be necessary
to quantify the mass rate of the feed or the product. The proposed
regulation would require that weigh scales be installed at the feed end
of calciners and bleachers and at the product end of dryers and predryers
unless the owner or operator of the source can present a method for
indirectly calculating these feed or product rates to an accuracy which
the Administrator determines is satisfactory.
9.9 IMPACTS OF REPORTING REQUIREMENTS
The proposed standards will require reports for notification of
construction, anticipated start-up, actual initial start-up, and physical
or operational changes. In addition, a performance test to determine
compliance and a demonstration of a continuous monitoring system will be
required for each emission source. Reports giving notification prior to
these tests and a report of the tests will be required. Excess emission
reports will be required four times a year. The operator will be required
to maintain records of any start-ups, shut-downs, and malfunctions of
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the control equipment or the continuous monitoring system. A file of
all measurements as described in Section 60.7(d) of the General Provisions
must also be maintained.
The total labor requirements for all respondents to collect and
prepare the required data during the first five years of the standard is
approximately 8,446 hours.
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APPENDIX A
EVOLUTION OF THE PROPOSED STANDARDS
The purpose of this study was to develop New Source Performance
Standards for the Sodium Carbonate Industry. Work on the study was begun
in April, 1978 by Radian Corporation under the direction of the Office of
Air Quality Planning and Standards (OAQPS), Emission Standards and Engi-
neering Division (ESED). The initial step of the study was a screening
study which concluded in October, 1978, with the recommendation that NSPS
be developed for the Sodium Carbonate Industry. Work then began on*Phase II
of the study.
The chronology which follows lists the important events which have
occurred in the development of background information for New Source Per-
formance Standards for the Sodium Carbonate Industry.
A-l
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Date
Activity
April, 1978
October 13, 1978
December 20, 1978
January, 1979
January 31, 1979
February 15, 1979
February 20, 1979
February 21, 1979
February 22, 1979
February 28, 1979
March 30, 1979
May 14-20, 1979
May 21-24, 1979
4
June 29, 1979
June, 1979
July 16-21, 1979
Screening study initiated
Screening study (Phase I) completed. A
decision was made to initiate standards
development.
Preliminary source test plan submitted.
Phone contacts with sodium carbonate plants
conducted.
Initial source test request submitted.
Plant visit to Texasgulf, Inc. in
Granger, Wyoming.
Plant visit to Kerr-McGee Chemical Corp.
in Trona, California.
Plant visit to FMC Corporation in
Green River, Wyoming.
Plant visit to Stauffer Chemical in
Green River, Wyoming.
Final source test request submitted.
Preliminary model plants submitted.
Emission tests at Plant A.
Emission tests at Plant B.
Final model plant parameters submitted.
Preliminary results of source tests at
Plants A and B received.
Emission tests at Plant C.
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Date
August 3, 1979
August, 1979
August 10, 1979
September, 1979
December 7, 1979
December 7, 1979
January 31, 1980
February 12, 1980
February, 1980
February 28, 1980
Activity
Cost analysis submitted.
Draft reports of source test results of
Plants A and B received.
Meeting to discuss basis for standards.
Results of source tests at Plant C received.
Working Group package mailed.
BID Chapters 3-8 mailed to Industry representatives
for review.
NAPCTAC package transmitted to committee members.
Industry and external group review packages mailed.
Steering Committee package mailed.
Docket transmitted to Washington, D.C.
NAPCTAC meeting.
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APPENDIX B
INDEX TO ENVIRONMENTAL CONSIDERATIONS
This appendix consists of a reference system which is cross
indexed with the October 21, 1974 Federal Register (39 FR37419)
containing EPA guidelines for the preparation of Environmental Impact
Statements. This index can be used to identify sections of the
document which contain data and information germane to any portion
of the Federal Register guidelines.
B-l
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APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
Information Document (BID)
1. Background and Description
of Proposed Action
Summary of Proposed
Standard
Statutory Basis for the
Standard
Facilities Affected
Process Affected
Availability of Control
Technology
Existing Regulations at
State or Local Level
The standards are summarized in
Chapter 1, Section 1.1.
The statutory basis for the
standard is given in Chapter 1,
Section 1.1.
A description of the facilities to
be affected is given in Chapter 3,
Section 3.2.
A description of the processes to
be affected is given in Chapter 3,
Section 3.1.
Information on the availability
of control technology is given
in Chapter 4.
A discussion of existing regulations
on the industry to be affected by
the standards is included in
Chapter 3, Section 3.3.
2. Alternatives to the Proposed
Action
Alternatives 1,2
Definition of alternatives
The definitions of alternatives
1,2 are presented in Chapter 6,
Section 6.2.
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Agency Guidelines for Preparing
Regulatory Action Environmental
Impact Statements (39 FR 37419)
Location Within the Background
Information Document (BID)
Environmental Impacts
Air Pollution
Water Pollution
Solid Waste Disposal
Energy
Other Impacts
Costs
The air pollution impact of the
control alternatives are considered
in Chapter 7, Section 7.1.
The impact of the control alterna-
tives on water pollution are
considered in Chapter 7, Section 7.2.
The impact of the control alterna-
tives on solid waste disposal are
considered in Chapter 7, Section 7.3.
The impact of the control alterna-
tives on energy use are considered
in Chapter 7, Section 7.4.
Other impacts associated with the
control alternatives are evaluated
in Chapter 7, Sections 7.5 and 7.6.
The impact of the control alterna-
tives on costs are considered in
Chapter 8, Section 8.2.
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APPENDIX C - SUMMARY OF TEST DATA
This appendix presents the results of the participate emission
»
tests and the visible emission measurements conducted at three different
plants. Results of organic emission measurements conducted at two of
these, and S0? measurements conducted at one plant are also presented.
The three plants where tests were conducted are identified as Plants
A, B, and C. The facilities tested at each plant were as follows:
1. Plant A
a. coal fired calciner and dissolver jointly controlled
with combined cyclone/ESP
b. rotary steam tube dryer with venturi scrubber
2. Plant B
a. gas fired calciner with combined cyclone/ESP
b. gas fired calciner with combined cyclone/venturi scrubber
c. fluid bed steam tube dryer with combined cyclone/venturi
scrubber
3. Plant C
a. rotary steam heated predryer with combined cyclone/
venturi scrubber
b. gas fired bleacher with combined cyclone/ESP
EPA Test Method 5 was used to determine the particulate concentra-
tion in the gas entering and leaving the control equipment of each
facility. EPA Test Methods 1 through 4 were used to determine other
characteristics of the gas stream required for the calculations appli-
cable under Method 5. Three particulate tests were performed at both the
inlet and the outlet of each emission control system with the exception
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of the combined coal fired calciner-dissolver system, where three tests
were made on the outlet emissions, but only two tests were made on the
inlet gas stream. The results of these tests are presented in Tables C-l
to C-4, C-7 to C-12 and C-16 to C-21.
Particle size distributions were determined at the inlet and outlet
of the control equipment for each facility with the following exceptions;
1) Particle size distributions were not determined at the outlet of
the venturi scrubbers on the dryers at either Plant A or Plant B due to
the high moisture content of the exhaust gas.
2) A particle size distribution analysis was not performed at the
outlet of the coal-fired calciner in Plant A.
These particle size tests were performed using an Andersen Cascade
Impactor. A Bacho size analysis was also performed on a composite sample
of collected particulates from the inlet tests. The results of these
measurements are presented in Figures C-l to C-20.
Visible emission measurements were conducted according to EPA Test
Method 9. The results of these measurements are presented in Tables C-5,
C-6, C-13 to C-15, C-22 and C-23.
The concentration of organics in the gas stream entering and leaving
the control equipment was determined for the calciners at Plants A and B.
Organics were analyzed on the basis of total hydrocarbons as methane using
a gas chromatograph. These results are summarized in Tables C-l, C-3, and
C-7 to C-12.
S02 measurements were conducted at the inlet and outlet of the
cyclone/ ESP on the coal fired calciner in Plant A using EPA Test Method
6. Three tests were completed on the outlet but only one inlet test was
completed. The results are presented in Tables C-l and C-2.
C-2
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C.I DESCRIPTION OF FACILITIES
Plant A. The coal fired calciner tested was controlled by a cyclone
and an ESP. Dissolver emissions in addition to the calciner emissions are
vented to this control equipment. The dissolver serves two trains and
the dissolver gas is vented to the control equipment of both calciners.
However, the gas flow rate and particulate rate from the dissolver are very
small in comparison to the gas flow and particulates from the calciner.
The calciner was operated at greater than 90 percent of normal
operating capacity during the tests. No abnormalities in the calciner
operating parameters were noted during the tests. During the second and
third EPA Method 5 tests the first collection field in the ESP was not
functioning. The average voltage and d.c. current in the first field
when it was operating were below normal. The remaining fields in the
ESP were operating normally throughout the tests. Plant personnel
reported that the first field was frequently out of service and that previous
tests had been conducted with it out.
The rotary steam tube dryer was operated at greater than 90 percent
of the design capacity during the tests. No abnormalities in the dryer
operating parameters were noted during the tests.
Plant B. The calciner controlled by a cyclone/ESP was operated at
greater than 90 percent of normal operating capacity during testing. No
abnormalities in calciner operating parameters were noted while testing
was underway. However, abnormalities were noted in the operating para-
meters of the first two fields of the ESP. The first field had an average
voltage of 144 volts and a d.c. current of 0.03 amps. The second field
had an average voltage of 204 volts and a d.c. current of 0.09 amps. For
both of these fields the voltage and current indicators showed wide
fluctuations. The third and fourth fields operated with voltages of 310
and 261 volts respectivley and d.c. currents of 0.45 and 0.71 amps re-
spectively. The first two fields also had high spark rates. Spark rates
for the first and second fields were approximately 50 and 55 sparks per
C-3
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minute, while for the third and fourth fields spark rates were less than
10 per minute. As a result of the abnormalities in ESP operation, the
test results at the ESP outlet are not representative of what can be
achieved with a properly functioning ESP.
The gas fired calciner controlled by a cyclone/venturi scrubber
operated at greater than 75 percent of normal operating capacity during
testing and no abnormalities in calciner operating parameters were noted.
This cyclone/venturi scrubber system was operated at an average pressure
drop of 94 cm (37") of water (approximately 85 cm (33.5") for the venturi
alone) and with an average L/G ratio of 0.44 1/m3 (3.3 gal/1000 acf).
At this pressure drop the venturi scrubber will not achieve as high a
removal efficiency as a four state ESP. As noted in Chapter 4, a pressure
drop of 150 cm (60") of water may be needed in a venturi scrubber to
achieve a removal efficiency comparable to that achieved by a four stage
ESP. Thus, the venturi scrubber at a pressure drop of 85 cm water does
not represent best available control technology.
The fluid bed dryer was operated at greater than 80 percent but at
less than 90 percent of normal operating capacity during the tests. No
abnormalities in dryer operating parameters were noted during any of the
tests with the exception of the first Method 5 test. During the initial
part of the first Method 5 test a lower than normal operating pressure in
the freeboard above the bed was noted. Also, a slightly higher amperage
was drawn by the dryer fluidizing air fans during the first Method 5 test
relative to the amperage these fans drew during the second and third
Method 5 tests. These differences in operating conditions between the
first test and the second and third tests may explain the large difference
in particulate emission results between the first test and the second and
third tests. The cyclone/venturi scrubber was operated at a pressure drop
of about 96 cm (38") of water (approximately 35" of water for the venturi
scrubber alone) during all tests.
Plant C. The emission control system for the predryers consists of
a cyclone for each predryer, and one venturi roc iCiuouci fui every two
C-4
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predryers. Thus, the exhaust gas from each precryer cyclone is combined
with the exhaust gas from one other predryer cyclone, and this combined
stream is treated in a single venturi rod scrubber. Because of this
arrangement, the inlets to two cyclones were tested while only one
venturi scrubber exhaust was tested. The two predryers were operated at
greater than 60 percent but less than 85 percent of their design capa-
city. On several occasions, predryer equipment failure occurred while
testing was underway. When these failures occurred, the tests were
stopped until the equipment was brought back on line and reached steady
state operating condition. However, after an equipment failure which
occurred prior to the first run of an EPA Method 5 test at the inlet to
the emissions control equipment on the first predryer, testing was
started before the equipment had reached steady state operating conditions.
As a result, the test results from this run were in error and will not be
used in subsequent analyses.
The cyclone/venturi scrubber system was operated at a pressure drop
of 46 cm (18") of water (about 43 cm (17") of water for the venturi
alone). Ambient air is admitted at the inlet to the venturi rod scrubber
for process control reasons. This ambient air accounts for the differ-
ence between the value of the outlet gas flow from the scrubber and the
value obtained by adding the gas flow rates measured at the outlet of
each predryer.
The emission control scheme for the bleachers consists of one ESP
simultaneously treating emissions from three bleachers. Each bleacher is
serviced by a separate cyclone. Two of the three bleachers were operating
during the tests. Thus, the inlets to two cyclones were tested along with
the exhaust from the one ESP- The two bleachers which were operational
during testing were operated at greater than 65 percent but less than
90 percent of design capacity. The gas flow rate to the emission con-
trol equipment on the bleacher was actually higher than the design gas
flow rate on a dry standard basis, and only slightly less than design rate
on an actual basis. This is due to the admission of ambient air between
the bleachers and the emission control equipment. (This ambient air is
emitted for process control reasons,)
C-5
-------
TABLE C-l. PLANT A: SUMMARY OF EMISSION TEST RESULTS,
COAL FIRED CALCINER INLET TO CYCLONE/ESP
Test no.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Particulate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg feed
Ib/ton feed
S00 Emissions
ppm
Ibs/ton feed
Organic emissions
ppm
One
5/23
1115-1250
90.4
205
401
19.8
117
51.2
191
383
30
Two
5/24
0800-1035
92.8
198
388
21.5
122
53.1
205
410
0.007
0.014
22
Average
-
91.6
202
395
20.6
119
52.2
198
396
26
C-6
-------
TABLE C-2. PLANT A: SUMMARY OF EMISSION TEST RESULTS,
COAL FIRED CALCINER OUTLET FROM CYCLONE/ESP
Test no.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (C°)
Temperature (F°)
Moisture (%)
Particulate emissions
g/Nm3 (dry)
gr/dscf
kg/Mg feed
Ib/ton feed
removal efficiency
S00 Emissions
Ppm
Ib/ton feed
Organic emissions
ppm
One
5/23
0848-1250
99.3
207
404
17.6
0.0779
0.0340
0.154
0.307
99.9
0.0038
0.0076
28
Two
5/23
1620-1804
101
205
401
16.9
0.0615
0.0269
0.121
0.241
99.9
0.00385
0.0077
32
Three
5/24
0807-0954
104
206
403
18.4
0.0157
0.00684
0.0284
0.0568
0.00345
0.0069
Average
-
102
206
403
17.6
0.0517
0.0226
0.101
0.202
0.0037
0.0074
30
C-7
-------
TABLE C-3. PLANT A: SUMMARY OF EMISSION TEST RESULTS
ROTARY STEAM TUBE DRYER - INLET TO VENTURI SCRUBBER
Test no.
General data
Date
Time
Isokinetic ratio (%)
Gas data
Temperature (°C)
Temperature (°F)
Moisture (%}
Particulate emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg dry product
Ib/ton dry product
One
5/21
1545-1705
147
86.1
187
52.7
73.8
32.3
34.2
68.4
Two
5/21
1745-1905
149
86.0
187
51.1
68.6
30.0
31.9
63.8
Three
5/21
0935-1200
121
86.9
189
61.1
76.9
33.6
33.8
67.6
Average
-
139
86.3
187
55.0
73.1
32.0
33.3
66.6
C-8
-------
TABLE C-4. PLANT A: SUMMARY OF EMISSION TEST RESULTS
ROTARY STEAM-TUBE DRYER -OUTLET FROM VENTURI SCRUBBER
Test no.
General data
Date
Time
Isokinetic ratio (%)
Gas data
Temperature (°C)
Temperature (°F)
Moisture (%)
Parti cul ate emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg dry product
Ib/ton dry product
Removal efficiency (%)
One
5/21
1440-1543
111
71.1
160
44.8
0.0840
0.0367
0.0325
0.0649
99.9
Two
5/21
1742-1845
94.2
71.1
160
31.7
0.0973
0.0425
0.0483
0.0966
99.9
Three
5/22
0916-1018
116
71.6
161
52.3
0.0788
0.0344
0.0343
0.0686
99.9
Average
^
-
107.0
71.3
160
42.9
0.0867
0.0379
0.0384
0.0767
C-9
-------
TABLE C-5. PLANT A: SUMMARY OF OPACITY OBSERVATIONS
COAL FIRED CALCINER - CYCLONE/ESP
Date Time 6-minute interval
5/23/79 1118-1218 1
2
3
4
5
6
7
8
9
10
1218-1248 1
2
3
4
5
6
7
8
9
10
Average opacity %
3
2
3
2
0
2
0
2
1
2
3
2
2
2
2
0
-
-
-
_
C-10
-------
TABLE C-5 (CONTINUED). PLANT A: SUMMARY OF OPACITY OBSERVATIONS
COAL FIRED CALCINER - CYCLONE/ESP
Date Time 6-minute interval
1612-1712 1
2
3
4
5
6
7
8
9
10
1712-1812 1
2
3
4
5
6
7
8
9
10
Average opacity %
2
3
1
0
0
0
2
1
1
1
0
0
0
0
0
0
0
0
0
0
C-ll
-------
TABLE C-5 (CONTINUED). PLANT A: SUMMARY OF OPACITY OBSERVATIONS
COAL FIRED CALCINER - CYCLONE/ESP
Date Time 6-minute interval
5/24/79 0815-0915 1
2
3
4
5
6
7
8
9
10
0915-1015 1
2
3
4
5
6
7
8
9
10
Average opacity %
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-12
-------
TABLE C-6. PLANT A: SUMMARY OF OPACITY OBSERVATIONS
ROTARY STEAM TUBE DRYER - VENTURI SCRUBBER
Date Time 6-minute interval
5/21/79 1515-1614 1
2
3
4
5
6
7
8
9
10
1615-1715 1
2
3
4
5
6
7
8
9
TO
Average opacity %
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-13
-------
TABLE C-6 (CONTINUED). SUMMARY OF OPACITY OBSERVATIONS
ROTARY STEAM TUBE DRYER - VENTURI SCRUBBER
Date Time 6-minute interval
5/22/79 0900-1000 1
2
3
4
5
6
7
8
9
10
1000-1100 1
2
3
4
5
6
7
8
9
10
Average opacity %
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-14
-------
TABLE C-7. PLANT B: SUMMARY OF EMISSION TEST RESULTS
GASFIRED CALCINER INLET TO C/ESP
Test no. 1 2 3 Average
General Data
Date 5/19 5/19 5/19
Time 1015 1430 1710
Isokinetic ratio (%} 78.1 93.2 104 91.9
Particulate Emissions
kg/Mg feed 215 191 133 180
Lb/ton feed 429 382 266 359
Organics
ppm 47 178 222 149
C-15
-------
TABLE C-8. PLANT B: SUMMARY OF EMISSION TEST RESULTS
GAS-FIRED CALCINER - OUTLET FROM C/ESP
Test no.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Particulate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg feed
Lb/ton feed
Removal efficiency
1
5/19
1014
94.9
205
401
30.4
0.213
0.0932
0.157
0.313
99.90
2
5/19
1420
103
205
401
30.4
0.282
0.123
0.206
0.411
99.9
3
5/19
1710
108
205
401
34.3
0.187
0.0819
0.123
0.246
99,9
Average
-
102
205
401
31.7
0.228
0.0994
0.162
0.323
Organics
ppm 361 314 - 338
C-16
-------
TABLE C-9. PLANT B: SUMMARY OF EMISSION TEST RESULTS
GAS-FIRED CALCINER - INLET TO CYCLONE/VENTURI SCRUBBER
Test no.
General Data
Date
Time
Isokinetic ratio (%)
Participate Emissions
kg/Mg feed
Lb/ton feed
Organics
ppm
1
5/15/79
0925
97.6
156
311
917
2
5/15/79
1345
97.9
227
454
2590
3
5/17/79
0810
111.1
182
364
-
Average
-
-
102.2
188
376
1750
a These organic measurements were made with the calciner operating at
low capacity, and may not be representative of normal operation.
C-17
-------
TABLE C-10. PLANT B: SUMMARY OF EMISSION TEST RESULTS
GAS-FIRED CALCINER - OUTLET FROM CYCLONE/VENTURI SCRUBBER
Test no.
Average
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Particulate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg feed
Lb/ton feed
Removal efficiency (%)
a
Orgam'cs
ppm
5/15/79 5/15/79
0930 1337
108 108
66.9
153
32.8
0.214
0.0935
0.15
0.299
99.9
154
76.0
169
36.4
0.278
0.122
0.216
0.432
99.9
261
5/17/79
0800
108
65.6
150
38.6
0.269
0.117
0.182
0.363
99.9
108
69.5
157
36.0
0.254
0.111
0.183
0.365
208
a These organic measurements were made with the calciner operating at
low capacity, and may not be representative of normal operation.
C-18
-------
TABLE C-ll. PLANT B: SUMMARY OF EMISSION TEST RESULTS
FLUID BED STEAM TUBE DRYER - INLET TO CYCLONE/VENTURI SCRUBBER
Test no.
Average
General Data
Date
Time
Isokinetic ratio (%)
Participate Emissions
kg/Mg feed
Lb/ton feed
Orgam'cs
ppm
5/18/79 5/18/79
0835 1220
72.6 68.8
115
231
25.0
52.5
105
88.0
5/18/79
1530
76.2
51.4
103
72.5
73.1
146
56.5
C-19
-------
TABLE C-12. PLANT B: SUMMARY OF EMISSION TEST RESULTS
FLUID BED STEAM TUBE DRYER - OUTLET FROM CYCLONE/VENTURI SCRUBBER
Test no.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Parti cul ate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg feed
Lb/ton feed
Removal efficiency (%)
Organics
ppm
1
5/18
0841
99.2
73.9
165
31.3
0.113
0.0494
0.081
0.162
99.98
103
2
5/18
1220
99.9
75.9
169
30.0
0.0390
0.0170
0.0271
0.0542
99.91
72
3
5/18
1520
94.9
61.2
142
29.2
0.150
0.00655
0.0109
0.0217
99.96
-
Average
-
-
98.0
70.3
159
30.2
0.0556
0.0243
0.0397
0.0793
87.5
C-20
-------
TABLE C-13. PLANT B: SUMMARY OFOPACITY OBSERVATIONS
GAS FIRED CALCINER - CYCLONE/ESP
Date Time Six-Minute Interval
5/19/79 1532-1632 1
2
3
4
5
6
7
8
9
10
5/19/79 0945-1045 1
2
3
4
5
6
7
8
9
10
Average Opacity (%)
13
12
13
17
16
24
17
10
9
13
12
13
14
14
13
14
12
11
12
12
C-21
-------
TABLE C-14. PLANT B: SUMMARY OF OPACITY OBSERVATIONS
GAS FIRED CALCINER - CYCLONE/VENTURI SCRUBBER
Date Time Six-Minute Interval Average Opacity (%}
5/15/79 1340-1440 1 50
2 40
3 45
4 50
5 45
6 40
7 40
8 40
9 38
10 38
C-22
-------
TABLE C-15.PLANT B: SUMMARY OF OPACITY OBSERVATIONS
FLUID BED STEAM TUBE DRYER - CYCLONE/VENTURI SCRUBBER
Date Time Six-Minute Interval
5/19/79 1203-1303 1
2
3
4
5
6
7
8
9
10
5/18/79 1410-1510 1
2
3
4
5
6
7
8
9
10
Average Opacity (%)
6
7
7
7
9
8
8
10
8
7
10
8
7
9
6
9
10
8
7
8
C-23
-------
TABLE C-16.PLANT C: SUMMARY OF EMISSION TEST RESULTS
Predryer-Inlet to C.yclone/Venturi Scrubber
Test No.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Participate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg feed
Lb/ton feed
I3 2
Cyclone Inlet
7/19/79 7/20/79
1715 1045
102.6 106
46.7 48.9
116 120
4.3 4.4
8.17 0.620
3.57 0.271
1.12
2.24
3
No.l
7/21/79
1015
105.9
53.3
128
5.0
0.281
0.123
0.499
0.998
Average
--
--
106
51.1
124
4.7
0.451
0.197
0.810
1.62
a. This test was discarded due to a low moisture content of
the dried product.
b. This average includes only tests 2 and 3.
C-24
-------
TABLE C-17. PLANT C: SUMMARY OF EMISSION TEST RESULTS
Predryer-Inlet to Cyclone/Venturi Scrubber
Test No.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Particulate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg Feed
Lb/ton feed
1
7/19/79
1147
91.1
43.3
110
6.1
0.261
0.114
0.419
0.838
2
Cyclone
7/19/79
1540
80.1
43.3
no
5.3
0.483
0.211
0.855
1.71
3
Inlet No
7/20/79
1100
93.7
43.3
110
6.2
1.49
0.653
3.15
6.29
4
.2
7/21/79
1035
92.6
45.0
113
5.4
1.43
0.625
3.21
6.42
Average
—
—
89.4
43.7
in
5.75
0.916
0.401
1.91
3.81
C-25
-------
TABLE C-18.PLANT C: SUMMARY OF EMISSION TEST RESULTS
Predryer-Outlet From Cyclone/Venturi Scrubber
Test No.
ld
2
3
4b
Average
General Data
Time
Isokinetic ratio (%)
Gas Data
7/19/79 7/20/79 7/20/79 4/21/79
1040 1200 2025 0928
100.3 105.9 106.2 105.1
Temperature
Temperature
Moisture (%)
Particulate
g/Nm3 (dry)
Gr/dscf
(
(
°C)
°F)
44
11
4.
.4
2
1
41
.7
107
4.
5
43
.9
111
6.
6
44.4
1
6
12
.2
Emissions
0.
0.
0256
0112
0.
0.
00938
0041
0.
0.
00938
0041
0
0
.0181
.0079
kg/Mg feed
Lb/ton feed
0.0247 0.0228 0.0307
0.0494 0.0456 0.0614
104
43.3
110
5.77
0.0123
0.0054
0.0261
0.0521
a. This test was discarded since only 1/2 of the traverse was
run because one of the predryers was shut down.
b. This test had a low gas flow rate, and low velocity head
read-ings.
c. This average includes only tests 2,3, and 4.
C-26
-------
TABLE C-19. PLANT C: SUMMARY OF EMISSION TEST RESULTS
Bleacher-Inlet to Cyclone/Electrostatic
Precipitator
Test No.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Parti cul ate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg feed
Lb/ton feed
l
7/16/79
1750
98.7
176
348
4.6
380
166
228
455
2
Cyclone Inlet
7/17/79
1150
102.3
174
345
6.1
297
130
161
321
3
No.l
7/18/79
0815
98.9
171
340
4.4
307
134
185
369
Average
—
--
100
173
344
5.03
328
127
191
382
C-27
-------
TABLE C-20.PLANT C: SUMMARY OF EMISSION TEST RESULTS
Bleacher-Inlet to Cyclone/Electrostatic
Precipitator
Test No.
General Data
Date
Time Started
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Particulate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg feed
Lb/ton feed
I3 2
Cyclone Inlet
7/16/79 7/17/79
1750 1115
104.0 104.4
217 180
423 356
0.5 7.3
277
121
152
303
3
No. 2
7/18/79
0755
111.9
172
341
4.4
104
45.6
53
106
Average
--
--
108
176
349
5.85
191
83.3
103
205
a. This test was discarded because a leak developed in the
sampling train during the test.
b. This average includes only tests 2 and 3.
C-28
-------
TABLE C-21. PLANT C: SUMMARY OF EMISSION TEST RESULTS
Bleacher-Outlet from Cyclone/Electrostatic
Precipitator
Test No.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (°C)
Temperature (°F)
Moisture (%)
Particulate Emissions
g/Nm3 (dry)
Gr/dscf
kg/Mg feed
Lb/ton feed
1
7/16/79
1738
99.4
106
222
3.2
0.0233
0.0102
0.0306
0.0611
2
7/17/79
1102
94.1
83.9
183
2.4
0.0124
0.0054
0.0192
0.0384
3
7/18/79
0744
98.1
78.3
173
2.4
0.00892
0.0039
0.0121
0.0241
Average
--
--
97.2
89.4
193
2.67
0.0149
0.0182
0.0206
0.0412
C-29
-------
TABLE C-22. PLANT C: SUMMARY OF OPACITY OPERATIONS
Predryer-Cyclone/Venturf:Scrubber
Date Time 6-minute interval
7/19/79 1100-1123 1
2
3
4
5
6
7
8
9
10
1710-1750 1
2
3
4
5
6
7
8
9
10
Average opacity %
0
0
0
0
-
-
-
-
-
-
0
0
0
0
0
0
0
-
-
-
C-30
-------
TABLE C-22 (Cont.) SUMMARY OF OPACITY OBSERVATIONS
Predryer-Cyclone/Venturi Scrubber
Date Time 6-minute interval
7/20/79 1215-1315 1
2
3
4
5
6
7
8
9
10
1315-1415 1
2
3
4
5
6
7
8
9
10
Average opacity %
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-31
-------
TABLE C-22 (Cont.) SUMMARY OF OPACITY OBSERVATIONS
Predryer-Cyclone/Venturi Scrubber
Date Time 6-minute interval
7/21/79 0930-1030 1
2
3
4
5
6
7
8
9
10
1100-1200 1
2
3
4
5
6
7
8
9
10
Average opacity %
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-32
-------
TABLE C-23. PLANT C: SUMMARY OF OPACITY OBSERVATIONS
Bleacher-Cyclone/Electrostatic Precipitator
Date Time 6-minute interval
7/16/79 1740-1840 1
2
3
4
5
6
7
8
9
10
1840-1940 !
2
3
4
5
6
7
8
9
10
Average opacity %
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-33
-------
TABLE C-23 (Cont.} SUMMARY OF OPACITY OBSERVATIONS
Bleacher-Cyclone/Electrostatic Precipitator
Date Time 6-minute interval
7/17/79 1100-1156 1
2
3
4
5
6
7
8
9
10
1640-1715 1
2
3
4
5
6
7
8
9
10
Average opacity %
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
-
—
—
J^
C-34
-------
TABLE C-23 (Cont.) SUMMARY OF OPACITY OBSERVATIONS
Bleacher-Cyclone/Electrostatic Precipitator
Date Time 6-minute interval
7/18/79 0800-0900 1
2
3
4
5
6
7
8
9
10
0900-1000 1
2
3
4
' 5
6
7
8
9
10
Average opacity %
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
C-35
-------
TABLE C-24.
PLANT A: SUMMARY OF INDUSTRY EMISSION TEST RESULTS,
COAL-FIRED CALCINER OUTLET FROM CYCLONE/ESP
Test no.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (C°)
Temperature (F°)
Moisture (%)
Parti cul ate Emissions
g/Nm3 (dry)
gr/dscf
kg/Mg feed
Ib/ton feed
One
9/14/78
1030-1140
99.95
227
440
16.0
0.0334
0.0146
0.070
0.140
Two
9/14/78
1340-1455
101.1
231
447
16. 5
0.0069
0.0030
0.0134
0.0268
Three
9/15/78
0920-1025
102.5
231
448
18.0
0.0043
0.0019
0.0091
0.0182
Average
101.2
229
445
16.8
0.0149
0.0065
0.0308
0.0617
C-36
-------
TABLE C-25. PLANT A: SUMMARY OF INDUSTRY EMISSION TEST RESULTS,
COAL-FIRED CALCINER OUTLET FROM CYCLONE/ESP
Test no.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (C°)
Temperature (F°)
Moisture (%)
Particulate Emissions
g/Nm3 (dry)
gr/dscf
kg/Mg feed
Ib/ton feed
One
10/19/78
1035-1150
105.0
211
412
8.52
0.0062
0.0027
0.0134
0.0268
Two
10/20/78
0910-1025
100.0
202
395
12.9
0.0092
0.0040
0.0220
0.0441
Three
10/20/78
1305-1425
101.5
206
403
14.2
0.0027
0.0012
0.0061
0.0123
Average
102.2
206
403
11.9
0.0059
0.0026
0.0138
0.0277
C-37
-------
TABLE C-26. PLANT A: SUMMARY OF INDUSTRY EMISSION TEST RESULTS,
COAL-FIRED CALCINER OUTLET FROM CYCLONE/ESP
Test no.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (C°)
Temperature (F°)
Moisture (%)
Particulate Emissions
g/Nm3 (dry)
gr/dscf
kg/Mg feed
Ib/ton feed
One
6/20/77
1000-1210
99.8
224
435
18.1
0.0261
0.0114
0.0426
0.0852
Two
6/21/77
1020-1235
99.0
216
420
17.6
0.0117
0.00511
0.0200
0.0400
Three
6/21/77
1255-1505
99.5
216
420
18.1
0.0186
0.00812
0.0303
0.0606
Average
99.4
218
425
17.9
0.0188
0*00821
0.0310
o:oei9
C-38
-------
TABLE C-27. PLANT A: SUMMARY OF INDUSTRY EMISSION TEST RESULTS,
COAL-FIRED CALCINER OUTLET FROM CYCLONE/ESP
Test No.
General Data
Date
Time
Isokinetic ratio (%)
Gas Data
Temperature (C°)
Temperature (F°)
Moisture (%}
Particulate Emissions
g/Nm^ (dry)
gr/dscf
kg/Mg feed
Ib/ton feed
One
6/14/77
1020-1240
107.5
228
443
16.9
0.0705
0.0308
0.127
0.253
Two
6/14/77
1310-1725
107.3
225
437
17.1
0.0323
0.0141
0.0575
0.115
Three
6/15/77
1000-1210
101.7
226
438
17.3
0.0181
0.00791
0.0319
0.0638
Average
105.5
226
439
17.1
0.0403
0.0176
0.072
0.144
C-39
-------
IOO.O
9O.O
ao.o
ro.o
90.0
30X3.
4O
JOO
2QO
99 99 99 9 99 8
PARTICLE SIZE DISTRIBUTION
99 98 95 90 80 70 6O 50 40 30 20 10 5 2 I OJ 0.2 O.I a05 O.OJ
100.0
Figure C-l.
Andersen Particle Size Analysis
Plant A
Coal Fired Calciner
Inlet to c/ESP
O.I
0.01 0.05 0.1 0.2 0.5 1
CUMULATIVE PER CENT BY WEIGHT LESS THAN(Dp)
C-40
-------
PARTICLE SIZE DISTRIBUTION
99.99 99.9 99.8 9996 95 90 80706050403020 10 » 2 1 OJ 0.2 0.1 0.05 0.01 ,ooo
Figure C-2.
Bahco Particle Size Analysis
Plant A
Coal Fired Calciner
Inlet (Composite Sample 2 Tests) to C/ESP
0.2
0.01 O.OS 0.1 0.2 OJ 1 2 5 ' 10 20 30 4O SO 60 70 80 90 95 98 99 998 999 99.99
CUMULATIVE PER CENT BY WEIGHT LESS THAN(Op)
O.I
C-41
-------
PARTICLE SIZE DISTRIBUTION
9999 99.9998 99 98 95 90 80 70 60 SO 4O 30 20 10 S
1 0.5 0-2 0.1 O.OS
Figure C-3.
Andersen Particle Size Analysis
Plant A
Rotary Steam Tube Dryer
Inlet To Venturi Scrubbers
20 X 40 SO 60 70 80
-PJL 100.0
BOO
70.O
•QO
300
400
30O
20.O
IOO
9.0 ^
•-0 £
7.0 «/>
z
4.0 O
IT
3.0 O
2
4.0
3.0 Ul
N
2.0
_J
O
>-
-------
PARTICLE SIZE DISTRIBUTION
99.99 99.9 99.8
99 98 95 90
1 0.5 0.2 0.1 0.05 0.01
80 70 60 SO 40 30 20
Figure C-40
Bahco Particle Size Analysis
Plant A
Rotary Steam Tube Dryer
Inlet (Composite Sample 3 Tests) to
Venturi Scrubber
aouo
TO.O
tOO
300
*OO
3O0
2QO
IQO
9.0 •£
io O
7.0 g
6.0 O
cc
3.0 O
S
3.0 Ul
M
2.0
O
K
(X
<
Q.
1.0
0.9
o.a
0.7
O.6
= 0 Ji
= . 0.4
= , 0.3
0.2
0.1
0.01 0.05 0.1 0.2 OS 1 2
80 90 95 9899
99.8 99.9 99.99
O.I
CUMULATIVE PER CENT BY WEIGHT LESS THAN(Dp)
C-43
-------
PARTICLE SIZE DISTRIBUTION
IOO.O
99.99 99.9 99.8 99 96 95 90 80 70 60 50 4O 30 20
10
2 1 0 £ 0.2 0.1 0.05 0.01
100.0
Figure C-5.
Andersen Particle Size Distribution
Plant B
Gas Fired Calciner Inlet (Test 1) to c/ESP
o.t
01 0.05 0 0.2 05 1 2 I1 20 30 40 SO 60 70 80 90 95 98 99 99.0 99.9 99.99
CUMULATIVE PER CENT BY WEIGHT LESS THAN(Dp)
O.I
C-44
-------
PARTICLE SIZE DISTRIBUTION
99.9B 99 9 99.» 99 98 95 90 80 70 60 50 «O 30 20 10 5 2 1 0.5 0.2 0.1_ 0.06 001 |OQ.O
9OO
7O.O
ftQO
.30.0
4OD
300
20.0
Figure C-6.
Andersen Particle Size Distribution
Plant B
Gas Fired Calciner Inlet (Test 2 ) to c/ESP
IOO
9.0 •£
8.0 O
7.0 £
e.o O
(T
5.0
-------
99.99 99.9 99.8
PARTICLE SIZE DISTRIBUTION
80 70 60 50 40 30 20 10 5 21 0.5 0.2 01 0.06 0.01
Figure C-7.
Andersen Particle Size Distribution
Plant B
Gas Fired Calciner Inlet (Test 3) to c/ESP =
10 20 30 40 50 60 70 80 90 95 9899
IOO.O
8OO
70.0
•GO
3OO
4OO
300
2QO
IQO
9.0 -3
ao £
7.0 «
6.0 O
(E
3.0 O
Z
3.0 UJ
N
tn
e.o «"
u
or
o.
i.o
O.I
0.7
0.6
0.3
0.4
0.3
0.2
O.I
O.I
001 0.05 0.1 02 0.5 1 2
CUMULATIVE PER CENT BY WEIGHT LESS THAN(Op)
C-46
-------
PARTICLE SIZE DISTRIBUTION
IOO.O
9O.O
•0.0
99.99 99.9 99.8 99 96 95 90 80 70 60 50 4O 30 20
1 0.5 0.2 0.1 0.05 0.01
03
0.2
0.1
M i 1
IOO.O
80O
7O.O
Figure C-80
Bahco Particle Size Analysis
Plant B
Gas Fired Calciner
Inlet (Composite Sample of 3 Tests) to C/ESP
1.0
o.e
0.7
o.e
o.s
0.4
0.3
0.2
0.01 0.05 0.1 02 03 1 2 S 10 20 30 40 50 GO 70 80 90 95 98 99 tt.8 99.9 99.99
CUMULATIVE PER CENT BY WEIGHT LESS THAN(Dp)
C-47
O.I
-------
IOO.O
99 99 99.9 99.8
PARTICLE SIZE DISTRIBUTION
9996 9S 90 8070605040 X 20 10 5 2 1 0.5 0.2 0.1 0.05 0.01
Figure C-9.
Plant B
Andersen Particle Size Distribution
Gas Fired Calciner
Outlet From C/ESP
IOO.O
800
7O.O
•00
300
4OO
300
20.0
IOO
9.0 "S
10 O
7.0 «O
z
6.0 O
-------
PARTICLE SIZE DISTRIBUTION
99.99 JS.9 99.8 99 98 95 90 80 70 60 50 40 30 20 10 5 ? 1 0.5 0.2 0.1 0.05 0.01
Figure C-100
Plant B
Andersen Particle Size Distribution
Gas Fired Calciner
Inlet to Cyclone/Venturi Scrubber
IOO.O
8OuO
TO.O
•ao
3QO
40O
3OO
2QO
IQO
9.O •£
8.0 O
TO v>
e.o O
or
s.o o
3.0 LU
ISI
2.0 »*J
O
h-
(T
<
a.
I.O
o.»
O.9
0.7
0.«
0.9
0.4
0.3
0.2
0.1
0.01 0.05 0.1 0^ 0-5 1 2 t 10 20304050607080 90 95 9899 99-8 99.9
CUMULATIVE PER CENT BY WEIGHT LESS THAN(Dp)
99.99
O.I
C-49
-------
PARTICLE SIZE DISTRIBUTION
IOO.O
99 99 99.9 99A
1 OJ 02 0.1 0.05 0.01
Figure C-110
Plant B
Bahco Particle Size Analysis
Gas Fired Calciner
Inlet to Cyclone/Venturi Scrubber
Composite of 3 Tests
IOO.O
0.01 O.OS 0.1 02 0.5 1
2 S 10 20 30 40 SO 60 70 80 90 95 98 99 M.8 99.9
CUMULATIVE PER CENT BY WEI3HT LESS THAN(Dp)
7O.O
eoo
300
4OD
30O
zao
9.0 •{£
8.0 0
7.0 £
a.o O
tr
s.o o
Z
*.O _
3.0 Ul
M
(O
2.0
O
H
ct
<
0_
1.0
O.S
0.7
o.e
0.9
0.4
0.9
0.2
O.I
C-50
-------
PARTICLE SIZE DISTRIBUTION
99.99 99.9 99.8
80 70 60 50 40 X 20
1 0.5 0.2 0.1 0.05 0.01
03
0.2
0.1
m
TT
Figure C-120
Plant B
Andersen Particle Size Distribution for
Gas Fired Calciner
Outlet From Cyclone/Venturi Scrubber
IOOJO
8OO
7O.O
«QO
5QO
4OD
ZOO
2O.O
IQO
9.0 *£
«•« £
7.0
-------
PARTICLE SIZE DISTRIBUTION
99.99 99999.8 99 96 95 90 80 70 60 50 40 3Q » 10 5 2 0.5 0.2 0 1 0.06 0.01
Figure C-13.
Plant B
Anderson Particle Size Distribution
Fluid Bed Steam Tube Dryer
Inlet to Cyclone/Venturi Scrubber
O.I
0.01 0-05 0.1 02 OJ5 1 2
10
20304050607080 90 95 9899
CUMULATIVE PER CENT BY WEIGHT LESS THAN(Dp)
C-52
aouo
70.O
eao
3QO
4OO
zoo
20.0
IOO
9.0
ao
7.0
e.o
8.0
4.O
3.0
o.
Q
-
-------
PARTICLE SIZE DISTRIBUTION
toao
9OJO
99.99 99.9 99.8 99 98 95 90 80 70 60 50 40 X 20
2 1 0.5 0.2 0.1 0.08 0.01 ,000
BOO
TOO
•ao
3QO
3OJ3
2QO
Figure C-14.
Plant B
Bahco Particle Size Analysis
Fluid Bed Steam Tube Dryer
Inlet (Composite of 3 Tests) To
Cyclone/Venturi Scrubber
1 00
8.0
7.0
O
a:
3.0
3.0 UJ
-------
10 99 99.9998 99 98 95 90 80 70 60 50 40 30 20
10
2 1 0.5 0.2 0.1 0.05 0.01
o
en
a.
o
in
c.
o
o
-------
99.99 99.9 99.8
99 98 95 90 80 70 60 50 40 30 20 10 5 2 1 0.5 0.2 0.1 0.05 0.01
..10
O
I
O1
cn
o.
Q
C
2
o
0)
N
•r~
CO
(0
D_
FIGURE - 16
Plant C
Particle Size Analysis
Rotary Steamheated Predryer #2
Inlet to Cyclone/venturi Scrubber
0. i
0.01 0.05
20 30 <0 50 60 70 80 90 95 98 99 99.8 99.9 99.99
Cumulative Percent by Weight less than (Dp)
-------
10 99.99 99 9 99.6 99 98 95 90 80 70 60 50 40 30 20 10 5 21 0.5 0.2 0.1 0.05 0.01
o
01
Q.
O
o
o
O)
N
•r—
00
O)
'u
•I—
-M
s_
-(-;;:,_ =i_;=:z|.,..?,
FIGURE C-17
Plant C
Particle Size Analysis
Rotary Steamheated Predryer
Outlet from Cylone/venturi scrubbe
O.i.
0.01 0.05 0.1 0.2 0.5
60 70 80 90 95 98 99 99.8 99.9 99.99
Cumulative Percent by Weight less than (Dp)
-------
o
en
Q.
O
!
u
N
U
•i—
-M
03
D_
10...
9
99.99 99.9 99.8 99 98 95 90
1 0.5 0.2 0.1 0.05 0.01
—10
_9
80 70 60 50 40 30
FIGURE C-18
Plant C
Particle Size Analysis
Bleacher #1
Inlet to Cyclone/electrostatic
Precipator
0. i
0.01 0.05 0.1 0.2 0.5 1
95 98 99 99.8 99.9 99.99
Cumulative Percent by Weight less than (Dp)
-------
10 99-99 99.9 99.6 99 98 95 90 80 70 60 50 40 30 20 10 5
1 0.5 0.2 0.1 0.05 0.01
..10
9...
o
I
en
oo
Q.
o
c
s
u
QJ
N
-------
1 O.S 0.2 0.1 0.05 0.01
O
I
cn
o.
Q
o
o
O
S-
(0
o.
10
9
...8
_7
Particle Size Analysis
Bleacher
Outlet From Cyclone/Electrostatic
Precipator
O.i.
o.oi
98 99
99.8 99.9 ' 99.99
Cumulative Percent by Weight less than (Dp)
-------
APPENDIX D - EMISSION MEASUREMENT AND CONTINUOUS MONITORING
D.I EMISSION MEASUREMENT METHODS
During the standard support test program for Sodium Carbonate Manu-
facturing plants, EPA conducted particulate emissions tests at three faci-
lities controlled with scrubbers and combinations of cyclones and electro-
static precipatators. Three tests were run before and after the control
device in accordance with EPA Method 5 (40 CFR Part 60 - Appendix A).
Method 5 provides detailed procedures and equipment criteria, and other
considerations necessary to obtain accurate and representative particulate
emission data. In addition, sulfur oxide emissions were determined in
accordance with EPA Method 6 (40 CFR Part 60 - Appendix A) and two of the
plants were sampled for organics. The samples were analyzed by an AID
model 621 portable Gas Chromatograph (GC) directly from a heated grab
sampling flask. Visible emission data were taken during the three EPA
tests in accordance with Method 9 (40 CFR Part 60 - Appendix A).
A few technical problems were encountered with the inlet testing
to control devices. These included high moisture, anisokinetic sampling at
one location, and an incomplete final run due to a process upset. However,
none of these problems were considered to cause significant errors in the
data. All of the outlet testing met the requirements of Method 5.
D.2 MONITORING SYSTEMS
The opacity monitoring systems that are adequate for other stationary
sources, such as steam generators, covered by performance specifications
contained in Appendix B of 40 CFR Part 60 Federal Register, October 6, 1975
are also technically feasible for sodium carbonate manufacturing plants
except where condensed moisture is present in the exhaust stream. When wet
scrubbers are used for emission reductions from sodium carbonate plants,
monitoring of opacity is not applicable; therefore, another parameter, such
D-l
-------
as pressure drop, would need to be monitored as an indicator of emission
control.
Equipment and installation cost for visible emission monitoring are
estimated to be about $18,000 to $20,000 per site. Annual operating cost
which include the recording and reducing the data, are estimated at about
$8,000 to $9,000 per site. Some savings in operating costs may be achieved
if multiple systems are used at a given facility.
Equipment and installation cost for monitoring scrubber pressure drop
and scrubbing fluid flow rate are estimated to be about $7500 per scrubber.
Annual operating costs, including examining and filing the data, would be
about $3300.
D.3 PERFORMANCE TEST METHODS
Consistent with the data base upon which the new source standards
have been established, the recommended performance test method for parti -
culate matter is Method 5 (Appendix A, 40 CFR 60 - Federal Register),
(December 23, 1971 as amended August 18, 1977). In order to perform
Method 5, Methods 1 through 4 must be used.
Subpart A of 40 CFR 60 requires that affected facilities which are
subject to standards of performance for new stationary sources must be
constructed so the sampling ports adequate for the performance test are
provided. Platforms access and utilities necessary to perform testing
at those ports must be provided.
Sampling cost for performing a test consisting of three Method 5
runs is estimated to range from $5,000 to $9,000. If in-plant personnel
are used to conduct the test, the cost will be somewhat less.
The recommended performance test method for visible emission is
Method 9 (Appendix A, 40 CFR 60, Federal Register, November 12, 1974).
D-2
-------
APPENDIX E. ENFORCEMENT ASPECTS
The recommended standards of performance will limit the emission of
particulates from affected facilities at new or modified sodium carbonate
production plants. The affected facilities are calciners, dryers,
predryers, and bleachers. The standard will be defined as a mass emis-
sion limitation in conjunction with a visible emission limitation.
Compliance with these standards can be achieved by installation of a dry
collection system (cyclone/electrostatic precipitator) or a wet scrubbing
system (venturi scrubber with or without a cyclone). Emissions from each
facility will be treated by a separate control system. Aspects of
enforcing these standards of performance are discussed below.
E.I PROCESS OPERATION
To ensure normal operation during enforcement testing the calciner,
bleacher, and dryer (including predryer) process weight rates should be
monitored. These parameters should be determined by direct measurement
or calculated using material balances based on sound engineering methods.
The standards will require the installation of belt scales at the proper
locations to measure feed or production rates unless the producer can
present an accurate method for indirectly calculating these rates.
For example, the production rate of the dryer can be calculated
using a correlation between production rates and steam usage rate. This
correlation may be based on prior production records, or detailed mass
and energy balances on the dryer.
The following is a method used at an existing direct carbonation
plant to calculate the predryer feed rate. Modifications may be nec-
essary if it is to be applied successfully at other direct carbonation
plants.
E-l
-------
Raw data required -
A = Alkalinity of the brine feed to the carbonators
B = Alkalinity of the supernatant liquor off the slurry from
the bicarbonate crystal lizers
C = Density of the filtrate from the bicarbonate filters (Ib/gal)
D = Filtrate flow rate (gpm)
E = % Impurity content of the feed on a dry basis
TPH of Feed = D X [A-B] X CX 1.59 X 10"4 ( T9P I"1" )
as pure Na2C03 ID nr
TPH of Feed = TPH of Feed X 1.58 ( I°" ^H^3 )
as pure NaHC03 as pure Na2C03 lon NA2UU3
TPH of Feed = r TPH of Feed i / n El
as impure dry L as pure Na«CO,J ' LI~tJ
NaHC0 * J
The bleacher feed rate can be obtained by assuming that there is no
loss of available Na2C03 between the predryer feed point and the bleacher
feed point, but that there is a process lag time which must be taken into
consideration.
E.2 DETERMINATION OF COMPLIANCE WITH A MASS EMISSION STANDARD
EPA test method 5 (40 CFR 60) will be used to determine the parti-
culate emissions from each affected facility. This test yields the con-
centration of particulates in the stack gas. Test methods 1 through 4
measure the stack gas volumetric flow rate and moisture content. These
data, coupled with the process weights of the affected facilities, will
be used to determine the emission rate on a unit of production basis.
The necessary process weight rates will be supplied by direct
measurements or engineering calculations (see Section E.I). These rates
include inlet feed rates to the calciner and bleacher and production
rates of the dryer and predryer. If weight rates are determined by
direct measurement, the belt scales must be properly calibrated before
the test.
E-2
-------
New facilities can and should be designed to ensure that the optimum
sampling conditions exist, even though the test methods allow for some
deviation from the desired conditions. As an example, for EPA test
method 1 the optimum location for the sampling point is at a distance
equal to 8 or more duct diameters downstream and 2 or more duct diameters
upstream of any expansion, construction, or other element which might
disturb the gas flow pattern.
E.3 DETERMINATION OF COMPLIANCE WITH A VISIBLE EMISSIONS STANDARD
The compliance testing of a visible emissions standard for particu-
late emissions requires only an observer trained in the reading of
visible emissions. These tests can be performed with little preparation
and require no advance notice to the producer. All visible emission
measurements will be performed according to EPA test method 9 for stack
emissions. When a scrubber is used this test method applies after the
steam plume has dispersed.
A bluish haze has been observed at the exhaust of several calciners
and may present a problem in the enforcement of the visible emission
standard. It is suspected that this haze is caused by either organics or
extremely fine parti dilates. Thus, enforcement of the opacity standard may
not be appropriate during periods when the blue haze is visible. In addition,
if this blue haze is found to impair compliance with the visible emission stan-
dard, the producer may petition the Administrator according to part 60
Section 113 to establish a new visible emission standard for that particular
calciner.
E.4 EMISSION MONITORING REQUIREMENTS
The recommended standards of performance do not require the in-
stallation of a continuous particulate monitoring system. However, the
use of continuous opacity monitors would ensure proper operation and
maintenance of the electrostatic precipitators. The continuous use of a
transducer and recorder to monitor the pressure drop of the venturi
scrubber would ensure that the pressure drop required to meet the parti-
culate standards is properly maintained.
E-3
-------
APPENDIX F
REPORTS IMPACT ANALYSIS
Comprehensive reporting of eaission data and control equipment
operating parameters are necessary in order to ensure compliance with
new source performance standards promulgated in accordance with Section
111 of the Clean Air Act. The reporting requiresents and their impacts
on industry and enforcement agencies are discussed in this appendix.
F.I REPORTING REQUIREMENTS
The purposes for collecting and maintaining the data required by
the proposed standards are to demonstrate compliance with the standards
and to ensure the proper operation and maintenance of the emission
control equipment. The proper operation and maintenance of the control
equipment will ensure continued compliance with the proposed standards.
A determination of the proper operation and maintenance of the control
equipment can be made by continuously monitoring control equipment
operating parameters or visible emissions. The enforcement branch of
the EPA or the state governments can use the data provided by this
monitoring to determine if an affected facility is properly operating
and maintaining the control equipment.
The proposed standards will require reports for the following:
1) notification of construction
2) notification of anticipated start-up
3) notification of actual initial start-up
4) notification of physical or operational changes
In addition, a performance test to determine compliance and a demonstra-
tion of a continuous monitoring system will be required for each emis-
sion source. Reports giving notification prior to these tests and a
report of the tests will be required. Excess emission reports will be
required four times a year.
The operator will be required to maintain records of any start-ups,
shut-downs, and malfunctions of the control equipment or the continuous
monitoring system. A file of all Eieasuresents as described in Section
60.7(d) of the General Provisions must also be maintained.
F-l
-------
The standards proposed apply only to affected facilities in the
natural process sodium carbonate industry. It is anticipated that
through the fifth year of applicability of the standard the following
facilities will be affected:
calciners (controlled by C/ESP) 2
t
dryers (controlled by VS or C/VS) 3
predryers (controlled by C/VS) 1
bleachers (controlled by C/ESP) 1
A continuous opacity monitor will be required for facilities con-
trolled by a cyclone/ESP or baghouse. A single monitor will be required
for each stack associated with the source. The alternative of monitoring
the operating parameters of the ESP would require the measurement of more
parameters and thus more extensive bookkeeping.
For facilities controlled by a venturi scrubber a continuous moni-
toring of operating parameters will be required. Transducers and re-
corders will be used to constantly record the pressure drop across the
venturi scrubber and the scrubber liquor supply. Two parameters would be
recorded for each venturi scrubber. There is one scrubber per source.
F.2 IMPACT ANALYSIS
This section will discuss the cost and burden required by the
respondent and the Enforcement Agency to collect, prepare, and use the
data required to determine compliance with the standard. Impacts are
expressed in terms of dollars and man-hours.
F.2.1 Respondent
The man-hours required to fulfill the reporting requirements are
presented in Table F-l. These hours were estimated using government
guidelines for non-mass produced sources. (The equipment is individually
designed, not mass produced.) The calculations are based on a five year
period and use the affected facilities discussed in Section F.I. It is
anticipated that there will be seven affected facilities subject to the
proposed standards in the five year projection. These facilities will be
spread between either two or three respondents.
F-2
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TABLE M.
SUMMARY OF MANHOURS NECESSARY FOR THE RESPONDENTS TO COMPLETE
REPORTING REQUIREMENTS
Tvoe of Report
Notification of Construction
Notification of Anticipated Start-up
Notification of Actual Initial Start-up
Notification of Physical or Operational Changes
Notification of Demonstration of the Continuous
Monitoring System
Continuous Monitoring Demonstration3
Maintenance of Records of Start-up, Shut-downs,
Malfunctions, and Periods of Inoperation of
the Control Equipment^
Excess Emission Reports0
Maintenance of a file of all Measurements
as described in Section 60.7(d) of the
General Provisions"
Notification of the Administrator Prior to a
Performance Test3
Performance Test Reports3
TOTAL
Hours/Report
2
2
2
-
2
8
8
80
8
40
80
2
2
40
40
Reports/Source
1
1
1
none
anticipated
1
1
2
5
15
5
5
1
2
1
2
Number of Sources
7
7
7
-
7
3
4
7
7
7
7
3
4
3
4
Total Hours
14
14
14
0
14
24
64
2800
840
1400
2800
6
16
120
320
8446
TJ
Co
3It is assumed that 50 percent of the sources will submit one report, and that 50 percent will submit two reports
It is assumed that 80 manhours per year are required to maintain these records. This impact analysis is
projected over 5 years. Thus, each year is considered as one report.
cEach source is required to submit four reports each year. It is assumed that three of these reports
will report no excess emissions and will require 8 hours per report, and that one report will report
excess emissions and will require 40 hours/report.
-------
The total cost to all respondents after five years is approximately
$92,900 (based on $11/man-hour). Each respondent would have a different
number of sources. Assuming three respondents (two with two sources, one
with three sources) the breakdown of expenses that would occur is pre-
sented in Table F-2.
The reporting requirements are small and would not significantly
affect any of the respondents' planning or budgets. These reporting require-
ments will be reviewed four years from the date of promulgation. This re-
vision process will include participation by affected parties and the
general public.1 At the end of the review period the reporting requirements
will be either extended or discontinued.
F.2.2 Enforcement Agency
The same basis used to calculate the respondent's labor requirements
and monetary expenditures are used to calculate the Agency's requirements.
The man-hours needed to meet the reporting requirements are presented in
Table F-3.
The total cost, in five years, to the Agency is approximately $9,420.
The cost would be $384 for the first year of the requirements and $130 for
each year afterwards.
The reporting requirements of the proposed standards are very small
and would not significantly affect any of the Agency's record keeping
requirements, planning, or budgeting. As noted in Section F.2.1, the
reporting requirements will be reviewed after four years.
F.2 REFERENCES
1. 44 F.R., May 29, 1979. pg. 30996-Appendix A.
F-4
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TABLE F-2. SUMMARY OF RESPONDENT LABOR AND COST BURDENS
Respondent
1
2
3
Number of sources
2
2
3
First year
man-hours
534
534
946
dollars
5870
5870
10,400
Each year after first
man-hours
368
368
672
dollars
4050
4050
7390
F-5
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TABLE F-3.
SUMMARY OF MANHOURS NECESSARY FOR ENFORCEMENT AGENCY
TO REVIEW THE REPORTING REQUIREMENTS
Type of Report
Review of Notification of Construction
Review of Notification of Anticipated
Start-up
Review of Notification of Actual
Initial Start-up
Review of Notification of Physical
or Operational Changes
Review of Notification of Demonstra-
tion of the Continuous Monitoring
System
Review of Continuous Monitoring
Demonstration Report3
Review of Excess Emission Reports
Review of Notification of the
Administrator Prior to a
Performance Test3
Review of Performance Tests9
Total
Hours/
Report
2
2
2
-
2
8
8
2
8
16
2
2
8
8
Reports/
Source
1
1
1
none
expected
1
1
2
15
5
1
1
2
1
2
Number of
Sources
7
7
7
-
7
3
4
7
7
7
3
4
3
4
Total
hours
14
14
14
0
14
24
64
210
280
112
6
16
24
64
856
alt is assumed that 50 percent of the sources will submit one report, and that
50 percent will submit two reports.
Each source is required to submit four reoprts each year. It is assumed that
three of these reports will report no excess emissions and will require 2
hours per report, and that one report will report excess emissions and will
require 8 hours/report. It is also assumed that twenty percent of the
reports of excess emissions will receive notices of violation. Sixteen
man-hours per notice of violation are required.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-80-029a
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Sodium Carbonate Industry - Background Information
for Proposed Standards
5. REPORT DATE
June 1980
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
Radian Corporation
3024 Pickett Road
Durham, North Carolina
27705
11. CONTRACT/GRANT NO.
68-02-3058
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
EPA 200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Standards of performance to control emissions of particulate matter from new,
modified, and reconstructed calciners, dryers, and bleachers in natural process
sodium carbonate plants are being proposed under Section 111 of the Clean Air Act.
This document contains information on the sodium carbonate industry and emission
control technology, a discussion of the selected emission limits and the
supporting data and the alternatives which were considered, and analyses of the
environmental and economic impacts of the proposed standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
Air pollution
Pollution control
Standards of performance
Sodium carbonate plants
Particulate matter
Soda ash
Air pollution control
13 B
18. DISTRIBUTION STATEMENT
Release unlimited. Available from EPA
Library (MD-35), Research Triangle Park,
North Carolina 27711
19. SECURITY CLASS (This Report!
unclassified
21. NO. OF PAGES
358
20. SECURITY CLASS (Thispage)
unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
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