&EFK
         United States
         Environmental Protection
         Agency
          Industrial Environmental Research  EPA-600/7-79-182
          Laboratory          August 1979
          Research Triangle Park NC 27711
Third Symposium on
Fugitive Emissions
Measurement and Control
(October 1978,
San Francisco, CA)

Interagency
Energy/Environment
R&D Program Report

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                 RESEARCH REPORTING SERIES


Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology. Elimination  of traditional  grouping  was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:

    1. Environmental Health Effects Research

    2. Environmental Protection Technology

    3. Ecological Research

    4. Environmental Monitoring

    5. Socioeconomic Environmental Studies

    6. Scientific and Technical Assessment Reports (STAR)

    7. Interagency Energy-Environment Research and Development

    8. "Special" Reports

    9. Miscellaneous Reports

This report has been assigned to the INTERAGENCY ENERGY-ENVIRONMENT
RESEARCH AND DEVELOPMENT series. Reports in this series result from the
effort funded under the 17-agency Federal Energy/Environment Research and
Development Program. These studies relate to EPA's mission to protect the public
health and welfare from adverse effects of pollutants associated with energy sys-
tems. The goal of the Program is to assure the rapid development of domestic
energy supplies in an environmentally-compatible manner by providing the nec-
essary environmental data and control technology. Investigations include analy-
ses of the transport of energy-related pollutants and their health and ecological
effects;  assessments of, and development of,  control technologies for energy
systems; and integrated assessments of a wide range of energy-related environ-
mental issues.
                        EPA REVIEW NOTICE


This report has been reviewed by the participating Federal Agencies, and approved
for publication. Approval does not signify that the contents necessarily reflect
the views and policies of the Government, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.

This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.

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                                     EPA-600/7-79-182

                                            August 1979
     Third Symposium on Fugitive
Emissions Measurement and  Control
  (October 1978, San Francisco, CA)
                     J. King, Compiler

            TRC - The Research Corporation of New England
                  125 Silas Deane Highway
                Wethersfield, Connecticut 06109
                  Contract No. 68-02-2615
                      Task No. 201
                 Program Element No. INE623
               EPA Project Officer: D. Bruce Harris

             Industrial Environmental Research Laboratory
              Office of Energy, Minerals, and Industry
                Research Triangle Park, NC 27711
                      Prepared for

            U.S. ENVIRONMENTAL PROTECTION AGENCY
               Office of Research and Development
                   Washington, DC 20460

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                                FOREWORD
The technical papers included in this volume were prepared for presentation
at the "Third Symposium on Fugitive Emissions:  Measurement and Control,"
held in San Francisco, California on October 23-25, 1978.

The objective of the Symposium was to provide a forum for the exchange of
information among concerned representatives of industrial, research and
governmental organizations relative to recent developments in industrial
and energy-related fugitive emissions measurement and control.  The
Symposium was sponsored by the Environmental Protection Agency's Industrial
Environmental Research Laboratory at Research Triangle Park, North
Carolina as part of its continuing effort to develop methods for the
measurement and control of airborne and waterborne fugitive emissions.

D. Bruce Harris of the Industrial Environmental Research Laboratory was
the Project Officer and General Chairman of the Symposium.

Joanne King of TRC - The Research Corporation of New England was the
Symposium Coordinator and Compiler of these Proceedings.

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                           TABLE OF CONTENTS
                   (Speakers'  names appeal' in italics.)


October 23. 1978                                                        Page

                               SESSION I

            Session Chairman:   D. Bruoe Harris, EPA/IERL-RTP

OVERVIEW OF THE FUGITIVE EMISSION PROBLEM - 1979 SIP REVISIONS 	   3
   David R. Dunbar, Chief, Policy Development, EPA/OAQPS

REGULATION OF FUGITIVE EMISSIONS UNDER THE CLEAN AIR ACT'S
PREVENTION OF SIGNIFICANT DETERIORATION (PSD) AND NON-
ATTAINMENT REQUIREMENTS  	  13
   Bradley I. Raffle, Environmental Counsel, TRC

THE IMPACT OF FUGITIVE EMISSIONS ON TSP CONCENTRATIONS IN
URBAN AREAS	37
   Ronald G. Draftz,  IIT Research Institute


                               SESSION II
          Session Chairman:  Dennis C. Drehmel, EPA/IERL-RTP

EMISSIONS AND EFFLUENTS FROM COAL STORAGE PILES  . -.	(39J
   T. R. Blaokwood and R. A. Wachter, Monsanto Research Corporation      -^

URANIUM MILL TAILINGS AREA FUGITIVE EMISSIONS  	  51
   Peter Piersol and P. G. Complin, James F. MacLaren Limited

IDENTIFYING SOURCES AND QUANTITIES OF FUGITIVE EMISSIONS IN
BALTIMORE	73
   Robert C, Koah and John T.  Schakenbach, GEOMET, Inc., and
   Kathryn G. Severin, IIT Research Institute

FUGITIVE EMISSIONS FROM THE BY-PRODUCT COKE OVEN PUSHING OPERATION ...  91
   Robert B. Jaoko, Purdue University

ESTIMATING DUST PRODUCTION FROM SURFACE MINING	103
   Karl F. teller, Bureau of Land Management, Douglas G. Fox,
   USDA Forest Service, and William E. Marlatt, Colorado State
   University

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                      TABLE  OF  CONTENTS  (Continued)


 October  24.  1978                                                        Page

                              SESSION  III

          Session Chairman:  Lyle D. Randen, AMAX  Coal  Company

 COMPARISON OF PREDICTED AND  OBSERVED EFFECTS OF  FUGITIVE  DUST
 FROM  COAL OPERATIONS	121
   Alexis W. Lemmon, 3v.3  Ronald Clark,  and Duane  A. Tolle,
   BATTELLE  Columbus Laboratories

 INDUSTRIAL NON-POINT SOURCES:   ASSESSMENT OF SURFACE RUNOFF  FROM
 THE IRON AND STEEL  INDUSTRY	137
   Gordon T. Brooknan3 John  A.  Ripp, and Bradford  C. Middlesworth,
   TRC

 DIFFERENTIAL TRACING OF OILY WASTE AND THE ASSOCIATED WATER  MASS
 BY TAGGING WITH RARE EARTHS	177
   D. L. MoCown, Argonne National Laboratory

 ESTIMATION OF FUGITIVE HYDROCARBON EMISSIONS FROM  AN OIL  REFINERY
 BY INVERSE MODELING  	  201
   Andrew A. Huang and Sara  J.  Head, AeroVironment Inc.

 MEASUREMENT  OF FUGITIVE EMISSIONS FROM PETROCHEMICAL PLANTS	229
   D. R. Tierney, I. S. Khan, and T. W.  Hughes, Monsanto  Research
   Corporation


                                SESSION IV
             Session Chairman:   James A.  Dorsey, EPA/IERL-RTP

 DEVELOPMENT  OF COATINGS TO REDUCE FUGITIVE EMISSIONS FROM COAL          ^^
 STOCKPILES	247
   /?.  S. Valentine, R. V. Kromrey, R. Naismith, and R.  S. Scheffee,
   Atlantic  Research Corporation

 NEW CONCEPTS FOR CONTROL OF  FUGITIVE DUST	271 '
   Dennis C.  Drehmel, EPA/IERL-RTP, and  Thomas Blackwood, Monsanto
   Research  Corporation, and S. Calvert, R. G. Patterson, and S. C.
   Yung, Air Pollution Technology, Inc.

BEST AVAILABLE CONTROL TECHNOLOGY (BACT) FOR FUGITIVE EMISSIONS
CONTROL IN THE STEEL INDUSTRY	281
   Arthur G.  Nioola, Pennsylvania Engineering Corporation

CONTROL OF FUGITIVE EMISSIONS AT REVERBERATORY FURNACES AND
CONVERTERS	313
   L.  V. yerino, R. T. Price, and T. K.  Corwln,  PEDCo Environmental,
   Inc., and Alfred B. Craig, Jr., EPA/IERL-CI

                                   iv

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                     TABLE OF CONTENTS (Continued)
                                                                        Page

CORE ROOM EMISSIONS IN FOUNDRIES	363
   William D.  Soott* Southern Research Institute and Robert C.
   Cummisford, Krause Milling Company


October 25, 1978


                               SESSION V
               Session Chairman:  Henry J. Kolnaberg3 TRC

FUGITIVE EMISSIONS PROBLEMS AND CONTROL AT A SURFACE COAL MINE 	 383
   Lyle D. Randen, AMAX Coal Company

AIRCRAFT TURBINE ENGINE PARTICULATE EMISSION CHARACTERIZATION., ..... 391
   John D. Stookham and Erdmann H. Luebcke, IIT Research Institute,
   and Larry Taubenkibel, DOT-Federal Aviation Administration

MEASUREMENT OF FUGITIVE DUST EMISSIONS FROM HAUL ROADS  	 415v
   Chatten Cowherd* Jv.f Midwest Research Institute

DEVELOPMENT OF MEASUREMENT METHODOLOGY FOR EVALUATING FUGITIVE
PARTICULATE EMISSIONS	431
   Edward E. uthe, Charles E. Lapple, Clyde L. Witham,  and Robert
   L. Mancuso, SRI International

DEVELOPMENT OF A FUGITIVE ASSESSMENT SAMPLING TRAIN  FOR PARTICULATE
AND ORGANIC EMISSIONS	443
   Roland L. Severance and Henry J. Kolnsberg, TRC

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          OCTOBER 23. 1978
     Monday Morning - SESSION I

Session Chairman:  D. Bruce Harris
                   Sanitary Engineer
                   EPA/IERL-RTP
   Monday Afternoon - SESSION II

Session Chairman:  Dennis C. Drehmel
                   Research Chemical Engineer
                   EPA/IERL-RTP
                  -1-

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 OVERVIEW OF THE FUGITIVE EMISSION PROBLEM -




             1979 SIP REVISIONS
                     By




               DAVID R. DUNBAR




OFFICE OF AIR QUALITY PLANNING AND STANDARDS




    U. S. ENVIRONMENTAL PROTECTION AGENCY
                Presented at




    Third Symposium on Fugitive Emissions




           Measurement and Control




            October 23 - 25, 1978




          San Francisco, California
                    -3-

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                                   ABSTRACT


     Fugitive emissions and fugitive dust and their associated impacts
will be a major consideration in the development of the 1979 State Im-
plementation Plans for those areas which are currently not attaining the
National Ambient Air Quality Standards.  Fugitive emissions and fugitive
dust will also play an important role in obtaining new source permits both
under PSD and new source review in nonattainment areas.  Specific guidance
will be presented on how fugitive emission/dust control will be factored
into the State plans for existing, as well as new, sources considering the
possible revision to the particulate matter standard.
                                   -4-

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     This paper summarizes some of the more important requirements of the
new Clean Air Act of 1977, especially those which relate to the fugitive
particulate matter problem—provisions that are already affecting, or
likely to affect, everyone in the near future whether they represent a
control agency, industry, or the general public.

     The past seven years have served as a major testing ground for the
fundamental goals of the Act.  Seven years after passage of the Act, vio-
lations of the National Ambient Air Quality Standards for one or more pol-
lutants still exist in more than half of the 247 air quality control regions.
As a result of the recent efforts required by Section 107 of the Act, to
designate areas as meeting, not meeting, or unclassified with respect to
the NAAQS, it was found that of the 3,215 counties in the United States 408
are listed as nonattainment for TSP.  (Figure 1)

     These standards were to have been attained by 1975; however, substan-
tial progress has been made.  For example, the estimated number of people
exposed to total suspended particulates in excess of the annual primary
standard decreased from 74 million in 1970 to less than 50 million in 1975;
in other words, the exposed population has been reduced by more than one-
third since the passage of the Clean Air Act of 1970.

     Despite the progress that has been made in reducing nationwide emissions
of air pollutants, failure to achieve the National Ambient Air Quality
Standards in many areas of the country represents the seven-year reality of
the implementation of the 1970 Act.  The Congress began to address the
reality of this situation more than three years ago and initiated the
drafting of the first comprehensive amendments to the Act since 1970.
During the course of these Intense deliberations in Congress, the Agency
merely tried to maintain an even keel while we were forced to balance the
realities of the non-attainment situation against the demands of  the
nation's emerging energy problems.

     Finally, with the recent enactment of the Clean Air Act Amendments of
1977, the Congress has reaffirmed its commitment to the goals originally
established by the 1970 legislation.  The new Amendments provide  a strong
mandate and make clear that Congress does not intend that the nation's
energy problem be allowed to compromise environmental quality.  The Act
strongly reaffirms our goals of attainment and the prevention of  signifi-
cant air quality deterioration.
                                    -5-

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               Figure 1.
                                                                          PRIflflRY NflROS
                                                                          NOT RTTHINEO
                                                                          IN tITIM COUN1T
                                                                          IN PMT OF COUM1T

                                                                          SECONORRY NflROS
                                                                          NOT flTTRINEO
                                                                          IN CUT me COUNTY
                                                                          IK mi Of COUNtT
PROMULGRTEO  LIST  OF  TSP  NON-RTTRINING COUNTIES  -  1978

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     To a large extent, the hardest phase of our efforts to meet ambient
air quality standards is yet to come.  The previously mentioned progress
has been achieved through the application of controls to sources generally
amenable to control requirements.  During this next round of control
efforts, agencies will be forced to concentrate on the less conventional
sources (fugitive dust, fugitive emissions) with which we have far less
control experience.  In other words, we have done the so-called easy things,
and what is left are the more difficult, less tried methods of air pollu-
tion control.  This is particularly true with respect to the attainment of
the TSP standard, as it must be attained by 1982.  Conventional stationary
sources have generally been controlled; however, in many cases, fugitive
emissions constitute a large percentage of total emissions.  A recent EPA
study on National Assessment of TSP1 indicates fugitive emissions add 15 to
25 ug/m3 to citywide average TSP levels.  However, significantly greater
impacts in vicinity of industrial sources were noted.  Additionally, as
part of this study, the contractor visited a number of industrial sites
within 14 cities.  Of all industrial sites, 32% were greatly impacted by
fugitive emissions.  Of industrial sites with annual means twice national
standard, all were influenced by fugitive emissions.  To some extent, the
new Act recognizes these difficulties and provides EPA with tools which
will enable the Agency to establish new regulatory requirements and new
approaches to difficult problems but also provides the flexibility to re-
solve isolated conflicts between environmental goals and energy, economic,
and employment concerns.

     The heart of the new Amendments focuses on the problem of attainment
in areas where the National Ambient Air Quality Standards continue to be
violated.  Each State that includes a nonattainment area must submit a plan
by January, 1979, for EPA approval by July, 1979, which provides for attain-
ment of the standards as expeditiously as practicable.  Congress took a
firm position on the issue of attainment.  The new State plan requirements
will necessitate in most cases the application of reasonable control meas-
ures and strict enforcement of these requirements for existing sources.
The plan will have to provide sufficient reductions in emissions to allow
room for growth, otherwise construction permits for new sources can be
granted only when more than offsetting emission reductions are secured on a
case-by-case basis prior to the facility start-up date.

     Control programs must be developed for each area which has been de-
signated as nonattainment.  These control programs must indicate how much
control will be needed.

     In developing each control program, the control agencies will be con-
sidering various alternatives for attaining the standards.  Once these
control alternatives have been considered, they should be screened to
determine what limitations may exist regarding each alternative.  However,
it should be noted that in most cases, because of the magnitude of the
problem, it will take all that one can think of to attain the standards.
                                   -7-

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      Emission reductions  for each alternative should be developed  to  deter-
 mine the effectiveness  of each program.   For photochemical  oxidants,  EPA
 has  developed control techniques  guideline  (CTG)  documents  to  provide some
 information on the percent of reduction,  etc.,  available for various  hydro-
 carbon control measures.   However,  no specific  CTG's have been developed
 for  TSP.   The Agency, however,  has  published various documents listed in
 Table 1 which will be useful in determining  the percent control for various
 particulate matter control measures.   However,  the most important  factor to
 consider in developing  a  control  strategy is that it be technically feasi-
 ble.

      The given strategy must provide  for  both attainment of the primary  and
 secondard standards for TSP.   The primary standard must be  attained as
 expeditiously as practicable but  no later than  1982  and the secondary
 standard must also be met by 1982.  However,  if more than RACT is  needed to
 attain the secondary standard,  a  reasonable  time  is  permitted.

      Once the strategy  has been selected  and it provides for both  attain-
 ment  and maintenance of the NAAQS,  the strategy must be adopted in the form
 of legally enforceable  procedures and submitted as a revision  to the  State
 Implementation Plan with  the Governor's approval.  This constitutes a com-
 mitment on the part of  the State  to implement and enforce the  plan.

      Where adoption by  1979 is  not  possible  (nontraditional controls  for
 particulate matter), a  schedule for expeditious development, adoption, sub-
 mittal,  and implementation of these revisions would  be  acceptable.  These
 schedules must provide  for implementation as  expeditiously  as  practicable.
 Prior to  attainment, these measures must  be  implemented rapidly enough to
 provide for emission reductions necessary to maintain reasonable further
 progress  as required by the action.   Schedules  would be a part of  the
 applicable SIP and would  represent  a  commitment on the  part of  the State  to
 meet  the  key milestones set forth in  the  schedule.

      Each plan must provide estimates  of  emission reductions for each
 adopted or scheduled control  measure  or for  related  groups  of measures
 where estimates of individual measures are impractical.   The Agency re-
 cognizes  that  estimates may change  as  measures  are more fully  analyzed and
 implemented.    As  estimates  change, these should be  revised and included in
 subsequent plan submissions  to  ensure  the plan  remains  adequate.

      Thus,  the 1979  SIP submission  for TSP must contain a demonstration  of
 attainment of  the  primary  standard as  expeditiously  as  practicable but no
 later than 1982, and emission limitations or regulations  for the control of
 traditional, as well as industrial, process fugitive particulate emissions.
 The plan may also  contain  schedules for the development,  adoption, and
 submittal  of controls of nontraditional sources.  These may include demon-
 stration studies,  etc.,  prior to  adoption for many nontraditional measures.
More  information on demonstration studies can be found  in "Guidelines for
Development of Control  Strategy in Areas with Fugitive  Dust Problems,"
OAQPS 1.2-071, pp  6-1 to 6-10.
                                   -8-

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                                   TABLE 1.

                          INFORMATION FOR DETERMINING
                            PERCENT CONTROL  FOR TSP
TSP

— CONTROLLED AND UNCONTROLLED EMISSION RATES AND
   APPLICABLE LIMITATIONS FOR EIGHTY PROCESSES, SEPTEMBER 1976.

   - EXTERNAL COMBUSTION
   - SOLID WASTE DISPOSAL
   - FOOD AND AGRICULTURE
   - METALLURGICAL
   - MINERAL PRODUCTS
   - WOOD PROCESSING
   GUIDELINE FOR DEVELOPMENT OF CONTROL STRATEGIES IN AREAS
   WITH FUGITIVE DUST PROBLEMS, OAQPS #1.2-071, OCTOBER 1977

   - UNPAVED ROADS
   - ENTRAINED STREET DUST
   - CONSTRUCTION AND DEMOLITION
   - AGRICULTURE
   - TAILING PILES
   - PARKING LOTS
   TECHNICAL GUIDANCE FOR CONTROL OF INDUSTRIAL PROCESS
   FUGITIVE PARTICULATE EMISSIONS, MARCH 1977, EPA 450/3-77-010

   - COMMON DUST SOURCES
   - IRON AND STEEL PRODUCTION
   - PRIMARY NON-FERROUS SMELTING
   - SECONDARY NON-FERROUS SMELTING
   - FOUNDRIES
   - MATERIALS EXTRACTION AND BENEFICIATION
   - GRAIN ELEVATORS
   - PORTLAND CEMENT
   - LIME
   - CONCRETE BATCHING
   - ASPHALT CONCRETE PRODUCTION
   - LUMBER AND FURNITURE
                                    -9-

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Impact of Potential Revision to Partlculate Matter NAAQS

     The Clean Air Act and EPA policy require a periodic reevaluation of
each NAAQS.  Under requirements, a program has begun to revise the air
quality criteria for particulate matter.  It is anticipated that a draft
revised document will be available for external review in late 1979.  Any
revisions  to the NAAQS for particulate matter that result from revision to
the criteria document would probably be proposed in mid-1980 and promul-
gated  in late 1980.

     Contrary to the position  taken by some, the Agency contends that the
current TSP standards are reasonable in light of available evidence.  The
standards  have  been under essentially constant  review  over the past  several
years, and the  Agency believes this position is widely supported by  the
scientific community.   This  is not to suggest that the TSP standards could
not be improved upon.   Many  reviews of  the standards have expressed  concern
 for the use of  TSP as  an index to health  effects  and indicate a need for
better characterization of  particulate  matter by  size  and chemical composi-
 tion.   The Agency shares the view that  any revision of the particulate
 matter criteria document should consider  the possibility of  defining a  more
 precise index of particulate matter pollution.

       It is possible that the revised criteria document will result in some
 form  of an "inhalable" particulate matter primary standard based on par-
 ticle sizes of less than 15 micrometers.

       Of course, until the criteria document is revised, any estimate of the
 effect is only speculation and therefore  should not be allowed to disrupt
 the current efforts to  develop SIP revisions in areas  designated nonattain-
 ment  for  particulate matter.   The SIP revisions must  still be submitted by
 January  1, 1979,  must  demonstrate attainment of  the current  particulate
 matter standard by December  31,  1982,  and must include emission regulations
  for conventional  sources and programs  to subsequently develop controls for
 unconventional sources as  required.

       If the reevaluation of the  criteria document results in the  kind  of
  change to the NAAQS discussed above, however,  some controls that  would be
  necessary to attain the current  NAAQS  may not be necessary  to attain a
  revised primary NAAQS.  Generally,  the sources in this category are those
  such as storage piles and materials handling operations that emit rela-
  tively large particles.

       The  1979 SIP revisions must contain or provide for the development of
  all  measures  necessary to attain the current  particulate matter standard.
  However,  it is legally permissible for  States which  adopt new regulations
  covering sources of predominantly large  particles to  recognize the possi-
  bility of a revision of the  current standard  in  establishing compliance
  schedules for such sources.   As long as compliance is required not later
  than 1982, such  schedules may include dates which are late  enough  so  that
  the  uncertainty  over  the particulate matter standard can be resolved  prior
  to significant expenditures for control.
                                     -10-

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     The possible revision of the particulate standard should not be a
factor which is considered in setting compliance schedule for sources other
than those described above.  Nor can this possibility affect any existing
compliance schedules.
New Source Review and Fugitive Dust
                                      •
     The Agency has set forth a position regarding the impact of industrial
process fugitive emissions and fugitive dust emissions on new source review
in general in the August 16, 1978, Fugitive Dust Policy, and for PSD in
particular in the June 19, 1978, final Regulations for the Prevention of
Significant Deterioration.

     Briefly, the Fugitive Dust Policy indicates that for new source review
in nonattainment urban areas, the current program which includes the emis-
sion offset concept remains unchanged.  However, since fugitive dust is re-
cognized as a significant air pollution problem in urban areas, it is
appropriate to allow sources to minimize either existing fugitive dust
sources or particulate stack emissions in order to satisfy their emission
requirements.

     There has been considerable concern about the location of major new
stationary sources in rural areas where fugitive dust has been determined
to be the major source.  New sources that wish to construct in rural areas
with infrequent short-term violations of the TSP standard should be allowed
to construct without the need of an emission offset, as long as they comply
with the appropriate emission regulation (NSPS, state regulation or BACT
for PSD source) and when considering their emissions, plus "non-urban"
background and the emissions from other stationary sources in the vicinity
of the proposed location, they do not cause violations of the NAAQS or
appropriate PSD increments.

     The June 19, 1978, regulations for PSD set forth a two-tier review
system.  Under the second tier, a source must apply best available control
technology.  In submitting a permit application with regard to BACT, the
source must propose BACT, set forth alternative systems, and then defend
the BACT selected.  BACT can include several technology options.  It must
cover all emission points, including stack emissions, fugitive process and
fugitive dust emissions.  It must be at least as stringent as NSPS, NESHAP,
and can include design, equipment or operating standards.

     Additionally, under the second-tier review, the source must conduct an
ambient impact review against both the NAAQS and increments.  However, the
June 19, 1978, regulations for PSD contained several exemptions regarding
ambient impact review.  One of those exemptions relates to fugitive dust.
Several comments were received regarding the proposed PSD regulations as
they related to fugitive dust emissions.  As a result of the comments, the
Agency will exclude from any air quality impact assessment of a source or
modification any fugitive dust emissions.  Additional support for this
exclusion can be found in the legislative listing.  It points to the utili-
zation of "administrative good sense" regarding the treatment of fugitive
dust.
                                     -11-

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     Certain aspects of this exclusion for fugitive dust should be noted.
First the burden of showing to what extent emissions from the proposed
source or modification would be made up of fugitive dust rests with the
applicant.  Second, the regulations do not exclude fugitive dust from the
determination of potential emissions.  Any source or modification which,
taking into account emissions of fugitive dust, would have potential emis-
sions equal to or greater than 250 tons per year would be subject to the
applicable PSD requirements, especially in many instances the BACT require-
ment.  Finally, EPA will treat emissions of fugitive dust as not consuming
increment for the purpose of evaluating other sources under PSD.

      It  should be emphasized that EPA  intends to implement the above policy
of  excluding the fugitive dust only  on an interim basis.  EPA will reassess
the implications of  the policy and any possible technical improvements  in
modeling fugitive  dust, and will adjust the policy  as appropriate.

      The Agency  realizes  the difficulty of the  task that  lies  ahead  to
develop adequate SIPs by  January,  1979, and to  fully implement those SIPs
by 1982.  The  Agency, in  developing  the requirements for  an  acceptable  SIP,
has tried to develop reasonable  and  achievable  goals that still meet the
 intent of Congress.   We have  tried to develop  requirements  that overcome
 barriers and make it as easy  as  possible  to develop SIPs  that will meet the
 intent of Congress.  Between now and January many tough decisions are going
 to have to be made.

      The challenge we are faced with is to achieve the cleanest air possible
 while maintaining the high standard of living the citizens of America have
 attained.  Fugitive  emissions control must begin now—we are beginning to
 more fully appreciate the problem, and fugitive emissions control must be
 considered in the current round of SIP revisions.  If not, we are only
 dealing with part of the air pollution control program, and we will fall
 short  of our goal of attaining the NAAQS as expeditiously as practicable.
                                  REFERENCES
  1.   National Assessment of the Urban Particulate Matter Problem,
       EPA 450/3-76-025, July, 1976.
                                      -12-

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      REGULATION OF FUGITIVE EMISSIONS






          UNDER THE CLEAN AIR ACT'S






   PREVENTION OF SIGNIFICANT DETERIORATION






    (PSD) AND NONATTAINMENT REQUIREMENTS
         BY:  BRADLEY I. RAFFLE, ESQ.




            ENVIRONMENTAL COUNSEL






TRC - THE RESEARCH CORPORATION OF NEW ENGLAND






           125 SILAS DEANE HIGHWAY






      WETHERSFIELD, CONNECTICUT  06109
                     -13-

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                                   ABSTRACT
     The Clean Air Act Amendments of 1977 have forced EPA and the States to
come to grips with the fugitive emissions problem.  Clearly, two of the most
significant forcing functions are the Act's new requirements for preventing
significant deterioration (PSD) and the new provisions relating to non-
attainment areas.  This paper focuses upon the control strategies for
fugitive dust and fugitive hydrocarbon emissions which EPA is using to
implement the PSD and nonattainment requirements of the Act for total sus-
pended particulate and photochemical oxidants/ozone.  These strategies focus
upon two basic areas:

     1)   Control of new fugitive emission sources under EPA's PSD
          preconstruction review requirements and/or the provisions
          of EPA's offset policy.

     2)   Control of new and existing fugitive emission sources
          under revised State implementation plans called for by
          the Act's PSD and nonattainment provisions.

     A separate issue concerns the extent to which ambient particulate con-
centrations attributable to fugitive dust should be considered in the ambient
air quality analyses required under the PSD and nonattainment procedures for
proposed new and modified stationary sources.  In areas subject to PSD require-
ments, the principal difficulty lies in distinguishing between natural and man-
induced fugitive dust.  In nonattainment areas, distinguishing between rural
and urban fugitive dust problems is a major problem issue.

     This paper explores the pertinent statutory and regulatory programs under
which EPA is attempting to deal with these problems.
                                      -14-

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1.0  INTRODUCTION

     Of the many regulatory consequences of the 1977 Clean Air Act Amendments,
one of the most significant Is the Increased attention they have generated on
the fugitive emissions problem.  Historically, EPA's implementation of the
Clean Air Act has focused on emissions from new automobiles and industrial
installations.  With respect to non-mobile sources of particulate matter,
regulations have been directed primarily at limiting the opacity and mass
loading of smokestack emissions from incinerators, fossil fuel-fired boilers
and major process industries.  Non-stack particulate controls have traditional"
ly been applied only to open burning and mineral extraction operations.

     Recent studies indicate that traditional stack-oriented control strate-
gies for particulate matter are insufficient by themselves to achieve the
ambitious air quality goals of the Clean Air Act.  Control of industrial
fugitive emissions and nontraditional sources of fugitive dust will therefore
be an essential ingredient in future control strategies for particulate
matter.  Control of new, and possibly existing, fugitive dust sources will
also be required in order to comply with EPA's new regulations on Prevention
of Significant Deterioration (PSD).  This paper attempts to summarize the
federal regulations and policies applicable to fugitive dust sources under
the recently amended Clean Air Act. Pertinent provisions of EPA's regulations
and guidelines for nonattainment areas and PSD areas will be discussed within
the context of the EPA Fugitive Dust Policy.
                                      -15-

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     OVERVIEW OF PSD AND NONATTAINMENT - SPECIAL RULES FOR FUGITIVE DUST

2.1  National Ambient Standards

     Any discussion of PSD and nonattainment should be preceded by an overview
of the fundamental statutory framework of the Clean Air Act for achieving and
maintaining the National Ambient Air Quality Standards (NAAQS).  The primary
purpose of the Act is to achieve and maintain air quality levels which are
protective of public health and welfare.  To this end, EPA is required to
establish National Ambient Air Quality Standards (NAAQS) for selected pollu-
tants emitted from diverse sources which could endanger public health or
welfare (criteria pollutants).1  (See Table I.)  The ambient standards are of
two types.  "Primary" standards are established at levels which will protect
public health while "secondary" standards are designed to protect public
welfare. As of October, 1978, EPA has promulgated NAAQS for six of the most
ubiquitous air pollutants including particulate matter (PM); sulfur oxides
(S0x); nitrogen oxides (N0x); carbon monoxide (CO); photochemical oxidants
(measured as ozone); and non-methane hydrocarbons (HC)*.2  An ambient standard
for lead was established in the Fall of 1978.3  It is the particulate matter
NAAQS which forms the statutory basis of fugitive dust control requirements
under the Clean Air Act.

     Attainment and maintenance of the ambient standards for the criteria
pollutants is the primary responsibility of the States.  Under Section 110 of
the Clean Air Act, each State is required to submit a State Implementation
Plan (SIP) for EPA's approval.  These plans set forth the State's strategy for
attaining and maintaining the standards within the time frames established by
the Act.  The required strategy must satisfy the eleven enumerated require-
ments contained in Section 110 of the Act, including programs for preventing
significant deterioration of clean areas and ensuring timely clean-up of
polluted areas.  Under the 1970 Clean Air Act Amendments (the foundation of
the current statute) all States were to have attained the primary (health-
related) standards by May 31, 1975 with the exception of a relatively few
areas where an extension to mid-1977 was granted.  Secondary standards were
to be attained within a "reasonable time," defined by most state plans to
coincide with the primary standard attainment date.4

2.2  Nonattainment

     Unfortunately, the 1970 Act did not specify the consequences of a state's
failure to attain the primary standards by the statutory deadline.  As the
deadline approached, however, at least 160 of the nation's 247 air quality
control regions (AQCRs) had monitored violations.  Many urban areas failed to
attain the particulate standards.
     *The hydrocarbon standard is designed only as a guide for assessing the
adequacy of State plans in attaining the photochemical oxidant standard.


                                      -16-

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                                                                      TABLE  I

                                                  NATIONAL AMBIENT AIR QUALITY  STANDARDS (NAAQS)
                                                                    40 CFR 50

                                           NATIONAL PRIMARY AMD SECONDARY AMBIENT AIR QUALITY STANDARDS
                                     (Expressed as Mlcrograns per cubic meter  [ug/ra3] at 25"C, 760 mm pressure)
-sj
 I
POLLUTANT
Sulfur Oxides (SOx)
(measured as 802)

Participates

Carbon Monoxide (CO)


2
Photochemical Oxldants

3
Hydrocarbons (I1C)


14
Nitrogen Dioxide (N02)
PRIMARY STANDARD
Annual
Mean
80


75

—



—


—



100
Maximum Concentration
(Allowed Once Yearly)
365
(over 24 hours)

260
(over 24 hours)
10 milligrams/m3
(over 8 hours)
40 milligrams/m3
(over 1 hour)

157
(over 1 hour)

160
(over 3 hours —
6-9 a.m.)

.»
SECONDARY STANDARD
Annual
Mean


1
60


Maximum Concentration
(Allowed Or.ce Yearly)
1300
(over 3 hours)

150
(over 24 hoursj

Same an Primary Standard




Same as Primary Standard




Same as Primary Standard



Same a;



i Primary Standard
                        1.  The 60 mg/n3 particulate standard is to be used only as a guide In  assessing the adequacy of  State
                        plans in achieving the 24-hour standard.

                        2.  EPA has proposed to relax the primary oxidant standard from 157 up  to 196 ng/rn3  (i.e.,  from 0.08
                        to 0.10 ppm).

                        3.  The hydrocarbon standerd Is to be used as a guide in assessing the  adequacy of oxidant control plans

                        4.  Pursuant to a mandate in the Clean Air Act, EPA is currently investigating the need  for  a short-term
                        (i.e. 1-3 hour) NOx standard.  EPA Is currently considering a one-hour  standard ranging from 470 co
                        940 mp,/m3.  The agency is expected to nuke a final decision on this matter in 1979.

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      The obvious legal dilemma created by these widespread failures concerned
 the legal "approvability"  of new sources which would add to levels of pollu-
 tion already in violation  of the law.   Section 110 of the Act,  which pres-
 cribed the July 1,  1975 attainment deadline,  did not provide for the conse-
 quences of failure.   EPA's regulations implemented this inflexible mandate by
 prohibiting the construction or modification  of any facility which would
 interfere with the  attainment or maintenance  of a national ambient standard.5
 Thus,  a strict reading of  the law would have  prohibited new sources from
 locating in any area which had failed  to attain the ambient standard for the
 pollutant(s)  it emitted.   The practical effect of such an interpretation was
 an end to growth in the developed areas of the United States.   EPA realized
 that the American public was unwilling to pay such a price,  even for clean
 air.

      EPA responded  to this problem with promulgation of its national Offset
 Policy on December  21,  1976.*6  The essence of the Offset Policy is that major
 new growth should be allowed in nonattainment areas only if air quality  is
 improved as a result of that growth.   This improvement comes by way of contem-
 poraneous emission  reductions from existing sources so as to more than "off-
 set"  the emissions  which will be added by the proposed new source.

      The Offset Policy imposes four substantial conditions on major new  or
 modified sources, including major sources of  fugitive dust,  seeking permits to
 expand in and around nonattainment areas.   First,  the source must reduce its
 emissions to  the lowest achievable emission rate (LAER).   Second,  it must be
 able  to certify that all sources which it owns or  controls in the same state
 are either im compliance or on a schedule of  compliance with the State imple-
 mentation plan.   Third, the new source must obtain emission  reductions from
 existing area sources which more than  "offset" the pollution to  be  added by
 the new LAER-controlled source.   These offsetting  emission reductions must
 exceed the proposed  new emissions by enough to represent "reasonable further
 progress" toward attainment of the ambient standards.   The fourth and final
 condition,  closely  related to the third,  requires  the owner  to  demonstrate
 that  the combination of LAER  and offsets  will  lead  to a net  air  quality
 benefit in the  affected area.

     Congress met the nonattainment issue head-on  in  the 1977 Clean Air  Act
 Amendments by continuing the  Offset Policy until mid-1979  and establishing a
 State  implementation plan  revision process  to  deal with the  problem after  that
 date.   Specifically,  Section  129  of the 1977 Amendments  provided  that  EPA's
 Offset  Ruling,  as it  may be amended, was  to remain  in effect, except  that  the
 baseline  for determining emission  offset  credit was changed  and  the source
 applicability was expanded.   By  January 1,  1979, the  States  must  submit  plan
 revisions  to EPA which  conform to  new  Part  D of  the Act.   These  revised  plans
 are designed to  replace EPA's  Offset Policy and must  be  approved  by no later
 than June  30, 1979.    Failure  to  adopt  and  receive EPA approval of the  revised
     *EPA is currently considering several significant changes to the policy.
These changes are not, however, expected to revise the basic format of the
current policy.  Special rules will be proposed for fugitive dust sources,
however, as discussed in Section 2.4 of this paper.
                                      -18-

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                 CHRONOLOGICAL DEVELOPMENT
                  OF EPA'S OFFSET POLICY
          AND THE ACT'S NONATTAINMENT PROVISIONS
7/1/75:   Original Deadline for Attaining the Primary NAAQS
            Promulgation of EPA's Offset Policy
                         12/21/76
             The 1977 Clean Air Act Amendments
                          8/7/77
   EPA Administrator's Memorandum Detailing the Criteria
    for Approving SIP Revisions for Nonattainment Areas
                          2/24/78
  EPA Promulgates List Designating PSD and Nonattainment
         Areas Pursuant to Section 107 of the Act
                          3/3/78
   EPA Promulgates Major Revisions to Its Offset Ruling
                           12/78
                  Revised SIPs Due to EPA
                          1/1/79
       Deadline for EPA Approval of  the Revised SIP
   (Failure to Obtain Approval by Deadline Triggers the
      Growth Ban Provision of Section 110(a)(2)(I).)
                          6/30/79
       New Deadline for  Attaining the Primary NAAQS
                         12/31/82
        Extended NAAQS Deadline for  Areas Unable to
    Attain the Oxidant and/or Carbon Monoxide Standards
                         12/31/87
                            -19-

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plan by this deadline triggers a statutory ban on major new sources (of the
nonattaining pollutant) in the nonattainment area.7  Until the revised SIPs
are approved and before July 1, 1979, the Offset Policy remains in fe-ree.

2.3  Prevention of Significant Deterioration

     The Act's silence on the nonattainment problem was matched by an equal
legislative vacuum on the issue of whether an area with air quality already
better than the national standards could allow its air to be "degraded" to the
national standards.  While the objective of the nonattainment provision is to
achieve and maintain the ambient standards, the purpose of PSD is to prevent
significant deterioration of air already cleaner than the ambient standards.

     The PSD controversy began as a result of a seemingly innocuous phrase in
the original Act stating that one of the Act's four basic purposes was to
"protect and enhance" the quality of the nation's air.  Relying primarily upon
this provision, environmental groups brought suit against EPA on May 24, 1972
to prevent the agency from approving State plans which failed to prevent
significant deterioration of clean air.8

     This challenge was ultimately successful and on December 5, 1974, EPA
promulgated regulations to prevent emissions of sulfur dioxide and particulate
matter from significantly deteriorating air quality in areas where concentra-
tions of those pollutants were lower than the applicable national ambient
standards. (39 FR 42510, Codified at 40 CFR 52.21).  EPA incorporated its PSD
regulations into the implementation plan of each State pursuant to Section
110(c) of the Act and established a procedure whereby EPA could delegate its
PSD responsibility to States.

     The regulations prohibited construction of stationary sources in any of
nineteen specified categories unless EPA (or a delegate State) had issued a
permit evidencing that the source would apply "best available control techno-
logy" (BACT) for S02 and for particulate matter and that emissions of those
pollutants would not cause significant deterioration of clean air.  For
determining what levels of deterioration were "significant," the regulations
set out an area classification system.  Under it, clean air areas could be
classified as Class I, II, or III.  In Class I areas, small increases of S02
and particulate matter would be significant; in Class II areas moderate
increases; and in Class III areas, increases up to an ambient standard.  The
regulations initially classified all clean areas as Class II, but gave States,
Indian Governing Bodies, and Federal Land Managers the opportunity to reclas-
sify their lands under specified procedures.

     The 1977 Amendments affirm the PSD concept.9  The new statutory scheme
follows the outline of the pre-existing regulations, but is generally more
comprehensive and restrictive.  Some of the more significant changes intro-
duced by the 1977 Amendments include:
                                      -20-

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       o  Formal Designation of PSD Areas  - Under  Section 107(d)  of  the new
          Act,  all areas with air quality  better than the national standards
          (or of indeterminate status)  must be formally listed by EPA.  EPA
          issued this list on March 3,  1978 (see 43 FR 8962).   Several revi-
          sions have been made since March 3,  1978.  (See 40 CFR 81.)

       o  More Restrictive "Increments" -  The  new law reduces  the allowable
          short-term increments for S02 and particulates in Class II and  III
          areas.  Class I increments remain the same.1^

       o  New Mandatory Class I Areas - The new Act retains the 3-class
          concept of the original PSD regulations and affirms the automatic
          Class II designation for most PSD areas. However, large national
          parks above a certain size which were in existence when the Amend-
          ments were enacted (8/7/77) are  now  designated as mandatory Class I
          areas.  These areas may not be redesignated.1*

       o  More and Different Sources Subject to PSD Review - The new Act
          increases the number of source categories subject to PSD precon-
          struction review from 19 to 28.   New and modified sources  within one
          of these 28 categories are subject to PSD if they have the poten-
          tial* to emit or increase emissions  by 100 tons per year of any
          pollutant regulated under the Act.  Furthermore, all new or modified
          sources, regardless of their category, are covered if they have the
          potential to emit 250 tons or more per year of any regulated  pollu-
          tant.12  Major sources of fugitive dust are covered by the 250-ton
          criteria.

       o  More Restrictive Definition of BACT  - Under the original PSD  regula-
          tions, Best Available Control Technology (BACT) could not  be  more
          restrictive than the New Source  Performance Standards (NSPS)  ap-
          plicable to the source category  being proposed.  Where NSPS had not
          yet been established for the applicable category, BACT was a  case by
          case determination which weighed economic, technological,  energy and
          geographic factors.  Under the new law, BACT is always a  case by
          case determination.  Where New Source Performance Standards (or
          hazardous emission standards) apply  to the proposed source, they
          represent a minimum, rather than a maximum, level of required
          control.  More importantly, BACT now applies to all pollutants
          regulated under the Act, not just S02 and particulate matter  as
          under the prior regulations.^

       o  Substantially Increased Monitoring and Modeling Requirements  -
          Under the original PSD Regulations,  applicants merely had  to  demon-
          strate, through atmospheric diffusion modeling, that the proposed
          emissions would not violate the  allowable increments. The  new la'w
     *The Amendments define a major source in terms of its "potential to emit"
but do not define the term "potential."  EPA's final PSD regulations define
"Potential to emit" as the capability at maximum capacity to emit a pollutant
in the absence of air pollution control equipment.
                                      -21-

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           Imposes  far more  sophisticated modeling  requirements.  In addition,
           air  quality and meteorologic monitoring  requirements may now be
           required both  prior  to  and after  construction.11*

        o   Other Criteria Pollutants to be Regulated  in the Future -
           EPA1s original PSD regulations applied only to S02 and particulates.
           While the new  law follows this policy on an interim basis, it
           directs  EPA to promulgate PSD regulations  for the other criteria
           pollutants (hydrocarbons, carbon  monoxide, photochemical oxidants,
           and  nitrogen oxides) by no later  than August 7, 1979.  These regula-
           tions will take effect  one year after promulgation and must ulti-
           mately be incorporated  into all State Implementation plans.  PSD
           regulations for lead must be promulgated in I960.15

     On November 3, 1977, EPA took four regulatory actions toward implementing
 the Act's  new  PSD  requirements.16  First, the agency promulgated amendments to
 the pre-existing PSD regulations, conforming them  to Section 168(b) of the new
 Act.  That section expressly made certain changes  "immediately effective" as
 of August  7, 1977  (i.e., new mandatory Class I areas; the new increments; and
 new Class  III  reclassification procedures).  The second action was the pro-
 posal of regulations giving guidance for the preparation of SIP revisions
 called  for by  the  new PSD requirements of the Act.  The third action was the
 proposal of comprehensive changes to EPA's  pre-existing PSD regulations,
 conforming them to the new  preconstruction  requirements of Section 165.  The
 fourth  action  was  a decision to implement the new  preconstruction review and
 BACT requirements  of Section 165 as of March 1, 1978.  Environmentalists had
 argued  for an  August 7,  1977 effective date while  Industry contended that the
 States  had sole authority to implement these new requirements through SIP
 revisions.

     EPA formally  promulgated its new PSD regulations and SIP revision guide-
 lines on June  19,  1978,  three and one-half months  after its original self-
 imposed deadline of March 1, 1978.17  Due to the widespread public awareness
 of the  March 1st date, however, EPA made the new PSD regulations retroactive
 to that date.  Thus, sources which failed to obtain all necessary air pollu-
 tion permits prior to March 1, 1978 will have to comply with the new PSD
 regulations.   Furthermore,  even those sources which did receive the necessary
 permits by March 1 will have to commence construction on or before March 19,
 1979 in order  to be exempt  from the new requirements.  This is the deadline
 for the submission of revised SIPs to EPA.

     As defined by the new  PSD regulations "fugitive dust" consists of native
 soil particles, uncontaminated by industrial pollutants, which become airborne
 through the forces of wind  or human activities.18  EPA has formally recognized
 the greater health impact of fugitive dust in urban as opposed to rural
 areas.  In general, the particulate matter found in rural areas is composed of
non-respirable native soil  particles.  Such particles are usually not exposed
 to potential contamination by Industrial pollutants and, therefore, present an
insignificant threat to public health.  By contrast, the native soil in indus-
 trialized urban areas is typically contaminated by a variety of potentially
harmful substances.
                                     -22-

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                CHRONOLOGICAL DEVELOPMENT OF
           PREVENTION OF SIGNIFICANT DETERIORATION

                 Sierra Club vs. Ruckelshaus
                           6/11/73

               EPA's Original PSD Regulations
                           12/5/74


              The 1977 Clean Air Act Amendments
                           8/7/77

          EPA Proposes Its Revised PSD Regulations
                 and SIP Revision Guidelines
                           11/3/77

       Effective Date of EPA's Revised PSD Regulations
   (Sources Receiving Permits After This Date Must Comply)
                           3/1/78

   EPA Promulgates List Designating PSD and Nonattainment
          Areas Pursuant to Section 107 of the Act
                           3/3/78


    EPA Formally Promulgates Its Revised PSD Regulations
                 and SIP Revision Guidelines
             (Note:  The Revised PSD Regulations
      Are Retroactively Effective as of March 1, 1978)
                           6/19/78

      Major Sources with Allowable Emissions in Excess
      of 50 Tons Per Year Will Have to Begin Submitting
            One Year's Continuous Monitoring Data
                           7/7/78

                   Revised SIPs Due to EPA
   (Note:  All Sources Commencing Construction After This
  Date Are Subject to the New PSD Requirements, Regardless
             of When They Received Their Permit)
                           3/19/79
Deadline for EPA Approval or Disapproval of the Revised SIPs
                           7/19/79
                            -23-

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      In light  of  such considerations  and  in recognition of  a substantially
 higher level of human exposure in urban areas,  EPA has  decided  to  focus  its
 fugitive dust  control efforts  in urban areas.   In rural areas,  controls  are
 recommended  for large man-made sources of fugitive dust such as tailing  piles
 and surface  mining  operations  which themselves  are causing  or contributing to
 NAAQS violations.*19

      For purposes of  PSD,  EPA  will not require  applicants to analyze  the air
 quality impacts of  emissions which qualify as "fugitive dust."   Nor will
 fugitive dust  emissions  consume the allowable PSD increments for particulate
 matter.   In  order to  qualify for this exemption,  however, applicants  will
 have to demonstrate that the emissions are indeed composed  of uncontaminated
 native soil.   It  should  also be noted that for  purposes of  calculating poten-
 tial emissions, fugitive dust  emissions will be included.   For  example,  while
 a  proposed surface  mining expansion with  a potential  fugitive dust emission
 rate in excess of 250 tons per year would be exempt from the PSD ambient air
 quality analysis  requirements,  it would not be  exempt from  the  other  require-
 ments of PSD such as  BACT.20

 2.4  Formal  Attainment Status  Designations

      The State Implementation  Plan revisions called for by  the  Act's  new PSD
 and nonattainment provisions are phrased  in a way which requires the  respec-
 tive boundaries of  a  State's PSD and  nonattainment areas be accurately de-
 fined.  Specifically,  Section 107(d) directs each  State  to submit a list  of the
 NAAQS attainment  status  of all State  areas to EPA.  EPA promulgation  of  the
 formal list, with any necessary modifications,  was required within 60 days of
 the submlttal  of  the  State lists.   This promulgation  appears in the Federal
 Register of March 3,  1978  (43  FR 8962,  Codified at 40 CFR 81, Subpart C).

      Section 107(d) specified  that  designations should  be based  upon  air
 quality  levels on the date of  enactment of  the  Amendments (August 7,  1977).
 States were  required  by  EPA guidance  to consider  the  most recent four quarters
 of  monitored ambient  air quality data available.   If  this data  showed no
 NAAQS violations, then the previous four  quarters  of  monitoring  data  were to
 be  examined  to assure that the  indication of attainment was  not  the result of
 unrepresentative  meteorologic  conditions.    In the  absence of  sufficient
 monitored air quality data, other  evaluation methods  were used,  Including air
 quality  dispersion modeling.
     *In general, a new major source to be located in a rural area with
infrequent short-term violations of the particulate NAAQS will be allowed to
construct after applying the required controls provided that the dust in
question is uncontaminated by pollutants from industrial activity and the
emissions of the source in conjunction with emissions from other sources in
the vicinity (excluding such dust) would not cause a violation of the ap-
plicable increment(s) or the applicable NAAQS, assuming as to the NAAQS an
appropriate "non-urban" background concentration.
                                     -24-

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     These Section 107(d) designations are subject to revision under Section
107(d)(5) whenever sufficient data is available to warrant a redesignation.22
Both the State and EPA can initiate changes to these designations, but any
State redesignation must be submitted to EPA for concurrence.  Private parties
must, therefore, work through the State or EPA to initiate a change in the
designations.

     The major significance of the 107 designations is not their impact on new
source preconstruction review, but rather on the SIP revision process.* Spe-
cifically, the formal designations of 107(d)(1)(A)-(E) are incorporated into
the SIP revision mandates of Part C (PSD) and Part D (Nonattainment) of the
Act.  Section 161 of Part C requires SIP revisions to prevent significant
deterioration in each area identified pursuant to Section 107(d)(l)(D) or (E).
Section 171(2) in Part D defines the term "nonattainment area" to include any
area identified under subparagraph 107(d)(l)(A) through (C), while giving EPA
authority to add other areas based upon monitoring or modeling data.  Designa-
tion as a "nonattainment area" triggers the SIP revision process of Part D and
a general ban on growth for nonattainment areas lacking an adequate SIP after
June 30, 1979.  Designation as a "PSD area" triggers the SIP revision process
of Part C.

     As noted in the preamble to the March 3rd Federal Register promulgation,
the designation of an area as attainment or nonattainment must be considered
only a point of departure and not as a final end in itself.23  Indeed, the Act
makes it clear that the designations are to be revised as appropriate to
reflect more current or accurate data.  It must also be noted that the desig-
nations will have only limited significance for new source revisions since
under both the PSD and nonattainment preconstruction review procedures, major
new and modified sources must undergo a preliminary modeling analysis to
determine their impact upon all nearby areas as well as the area in which they
will be located.  Thus, case by case impact analysis is required to determine
the impact on all neighboring areas and also to account for the possibility
that an area with a particular designation may encompass "pockets" which do
not fit that designation.

     For designations of total suspended particulates  (TSP), the localized
nature of the violations precluded the use of general area-size criteria.
States are therefore advised that designations along political boundaries
such as city or county lines were practical from an air quality management
standpoint. In the case of particulates, however, one very difficult problem
was the appropriate designation of rural areas with significant levels of
fugitive dust.  As noted earlier, EPA's Fugitive Dust Policy recognizes the
generally greater health impact and toxicity of urban as opposed to rural
fugitive dust.  Therefore, for the purposes of these designations, rural areas
experiencing TSP violations which could be attributed to fugitive dust could
claim attainment of the particulate NAAQS.  Rural areas for this purpose are
defined as those which have:  (1) A lack of major industrial development or
the absence of significant industrial particulate emissions, and  (2) low
urbanized population densities.21*
                                      -25-

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     The attainment status designations are very important with respect to
major new fugitive dust sources.*  Specifically, under EPA's soon to be
revised Offset Ruling, major fugitive dust sources locating in clean portions
of formally designated nonattainment areas or in attainment or unclassified
areas shall be subject only to applicable requirements for preventing signif-
icant deterioration of air quality (see 40 CFR 52.21).  Thus, only those
major new fugitive dust sources locating in actual nonattainment areas will
be subject to the Offset Ruling.**
     *Under both the Offset Policy and the PSD regulations the term "fugitive
dust" refers to particulate emissions composed of soil which becomes suspended
either by the forces of the wind or man's activity.   This would include
emissions from unpaved haul roads, wind erosion of exposed soil surfaces and
soil storage piles and other activities in which soil is either removed,
stored, transported, or redistributed.

     **Even where the Offset Ruling is applicable to a major new or modified
fugitive dust source, the soon to be revised Offset Policy exempts these
sources from the requirement of demonstrating a "net air quality benefit"
(Condition 4).
                                     -26-

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3.0  SIP REVISIONS FOR NONATTAINMEN't AREAS - NEW FOCUS ON FUGITIVE DUST

3.1  Geographic Consideratleas

     In analyzing partlculate pollution, It Is necessary to distinguish
between rural and urban nonattainment areas.  The sources and characteristics
of particulate pollution in urban areas are fundamentally different from the
rural counterparts.  The most important distinction is the generally greater
human health impact of urban particulate pollution.  This is true in both a
quantitative and qualitative sense in that urban particulate not only affects
more people, but also is more hazardous than rural particulate matter.
Indeed, contaminated urban fugitive dust, coupled with potentially hazardous
direct industrial particulate emissions in urbanized areas, is one of the most
serious air pollution problems facing the nation from a public health stand-
point.

     By contrast, rural particulates frequently consist of windblown native
soil particles.  Although these rural fugitive dust emissions are often the
result of human activities such as agriculture, surface mining and quarrying
operations, the actual particles are typically in the non-respirable size
range and are uncontaminated by industrial pollutants.  EPA's recent Fugitive
Dust Policy recognizes the fundamental distinctions between rural and urban
nonattainment problems for suspended particulates.  Specifically, the policy
provides that major emphasis for fugitive dust control in nonattainment SIP
revisions should center on urban areas.  It should be noted, however, that
this general exemption for rural nonattainment does not extend to rural areas
where traditional industrial particulate sources are causing or contributing
to the NAAQS violations.  These areas are treated the same as urban nonattain-
ment areas.

     With these geographic considerations as a backdrop, it becomes obvious
that TSP nonattainment strategies will focus primarily on major metropolitan
areas. Nearly 70% of the Nation's urbanized areas with populations exceeding
200,000 have been designated nonattainment for TSP.*  Thus, the remainder of
this section will focus on the issues inherent in developing acceptable TSP
strategies for urban nonattainment areas.

3.2  Sources of Urban Particulate

     For purposes of regulatory control strategy development, urban particu-
late sources are categorized either as traditional or nontradltional.  The
distinction is significant in terms of the types of control strategies re-
quired in the 1979 SIPs.  Traditional sources, as the name implies, refer to
those industrial sources which have been regulated under earlier SIPs.  Both
stack and fugitive emissions associated with such sources must, to the extent
     *Some suprising and noteworthy exceptions to the general nonattainment
status include New York-NE New Jersey, Philadelphia, and Detroit.


                                      -27-

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 necessary,  be controlled through formally-adopted regulations in the 1979 SIP
 submittals.25  Nontraditional sources are those which generally have not been
 controlled  in the past.   These include emissions from construction activities,
 demolition  operations and resuspended street dust.   By their nature, nontradi-
 tional sources are not amenable to the kind of straightforward emission
 limitations or design standards typically applied to traditional sources.   The
 relationship between these nontraditional emissions and resultant ambient air
 quality concentrations has never been adequately defined.   The development of
 emissions factors,  modeling techniques,  and effective control strategies for
 these complex sources will take time and study.

      The SIP revision memorandum of February 4,  1978 recognizes these problems
 and authorizes states to submit control program schedules  (as opposed to
 formal regulations)  for  control of nontraditional particulate sources.26
 These schedules must call for the expeditious development,  adoption, submittal
 and implementation of the necessary control measures.   For  nontraditional
 particulates,  field studies and demonstration projects to define the problem
 and investigate alternative controls should begin as soon as possible.   If
 these studies reveal that major nontraditional control efforts are needed to
 meet the 1982 NAAQS deadlines,  implementation of the required controls  prior
 to  the deadline will be  necessary.

      The significance of nontraditi6nal  sources  to  the TSP  nonattainment
 problem has become apparent as  traditional  source control programs have
 failed to achieve ambient standards.   In Greater Pittsburgh,  for example,
 modeling of inventoried  traditional sources is able to account for only 15% of
 measured TSP concentrations at  certain monitors.  Assuming  the reliability of
 the model estimates and  the accuracy of  the traditional source emissions
 inventory,  this means that fully 85% of  ambient  particulates are of nontradi-
 tional origins.   One of  the most significant  findings  of the 1976 National
 Particulate Assessment is that  particulates from nontraditional sources con-
 tribute 25  to 30 yg/m3 to citywide TSP levels,  thereby preventing many  urban
 areas from  attaining the ambient standards.27

      These  nontraditional particulate emissions  are the product of everyday
 urban activities.   Five  major nontraditional  source categories have been
 isolated in urban areas.   These include  reentrained street  dust,  construction
 and demolition operations,  exhaust  (and  tire)  particles from automobiles,  dust
 from unpaved roads  and secondary particulates.   The impact  of these sources
 depends upon factors such as meteorology, topography,  soil  characteristics,
 road patterns  and many other variables which  control the impact of wind or
 traffic on  surrounding particles.  As  a  general  rule,  however,  their air
 quality impact is more localized  than  stack emissions.   As  such,  SIP revisions
 relating to  nontraditional  sources will  have  to  be  rather site and source
 specific.

      Recent  evidence indicates  that wind  and  vehicle-induced  reentrainment of
 street  dust  is probably  the  largest  source  of  particulate matter  in many
 downtown  areas.   Depending upon  the amount  and type of  road dust,  as well  as
 the  speed and  level  of traffic and wind  conditions, reentrainment  may con-
 tribute  from 14-20 yg/m3  to  ambient TSP  levels.28   The  potential  toxicity  of
many  of  these particles,  coupled with  the high level of  human  exposure  to
 them, would seem  to  demand heightened  regulatory attention  to  this  problem.
                                      -28-

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     Automotive-related particulate emissions from tail pipes and tire wear
are closely related to the reentrainment problem since much reentrained
particulate originates from the automobile.  The states' failure to address
this problem creates a serious regulatory deficiency in that such emissions
have potentially harmful health effects.  For example, lead emissions from
automotive exhaust contribute as much as 4 pg/m3 in certain cities.29  Such
concentrations are believed to produce nervous system damage in children.30

     The air quality impact of construction and demolition activities is also
substantial in terms of total particulate loadings.  These emissions are
similar to those from unpaved areas generally in that they result from both
wind erosion over exposed soil surfaces and man's physical activities on the
surface.  Heavy construction projects such as roadway construction and resi-
dential, commercial or industrial developments are clearly the largest con-
tributors in this category. Field studies indicate an average dust generation
rate of 1.2 tons of particulate per acre per month.31  Applying this emission
factor to a 150-acre residential construction project, the 100-ton major
source threshold is exceeded in less than 3 weeks.

     Another TSP source not addressed in earlier SIP strategies is "secondary
particulate."  Secondary particulates are the products of chemical reactions
occurring in the atmosphere through forces of sunlight, temperature and
meteorology in the presence of water vapor and gaseous atmospheric pollutants
such as S02 and NO .  Found in both rural and urban areas, secondary particu-
lates are composed primarily of sulfates, organics and nitrates.  They are a
prime component of urban smog and are a major contributor to ambient TSP
levels.

3.3  Control Strategy Development

     From a conceptual standpoint, development of revised control strategies
for TSP is a seven step process beginning with problem definition and ending
with an adopted strategy demonstrating attainment of the 75 yg/m3 primary
standard before 1983.  These seven steps include:

       o  ANALYSIS OF EXISTING AIR QUALITY DATA
       o  DEFINITION OF THE CONTROL AREA
       o  PREPARATION OF AN EMISSION INVENTORY
       o  ESTABLISHMENT OF SOURCE/AIR QUALITY RELATIONSHIPS
       o  EVALUATION OF ALTERNATIVE CONTROL STRATEGIES
       o  ANALYSIS OF ESTIMATED AIR QUALITY IMPROVEMENT
       o  SUBMITTAL OF AN APPROVABLE SIP REVISION

     STEP 1 - Analysis Of Existing Air Quality Data
                                   •
     Determination of the attainment status of an area is based upon measured
TSP values at selected monitoring locations.  High-volume samplers measure TSP
concentrations at these monitoring sites by drawing ambient air through a
particulate filter at a specified flow rate.  The collected particles are then
weighed and the results expressed in terms of micrograms per cubic meter of
sampled air.
                                       -29-

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      The  purpose of  the ambient air quality analysis is to  determine  the
 validity  and  representativeness of  measured TSP  concentrations.  Assessing  the
 validity  of measured TSP levels is  essentially a matter of  determining  that
 appropriate measurement techniques  and  quality control  procedures  have  been
 employed. Assuming the  data  is  valid, procedures must then  be  employed  to
 determine whether it is representative  of  either a broad or confined  area.
 Once  the  relationship between monitored data and contributing  sources is
 established,  it  can  then be  used in a meaningful way to determine  the actual
 origins of the nonattainment problem.

      STEP 2 - Definition Of  The Control Area

      Based upon  the  results  of  the  air  quality analysis,  the next  step  in the
 SIP revision  process is to determine the boundaries of  the  area  to be con-
 trolled.  This determination  is  based upon  the geographic scope of  the nonat-
 tainment  problem, and the location  of the  sources causing that problem.  Both
.of these  factors should have been defined  in the air quality analysis.

      STEP 3 .- Preparation Of An Emission Inventory

      Having defined  the origins and geographic scope of the nonattainment
 problem,  it is necessary to  quantify the problem.   This is  accomplished by  an
 emission  inventory.   This inventory allows  strategists  to assess the  relative
 contributions to various sources and to determine the emission reduction
 impact of alternative control options.

      As a practical  matter,  many states simply will not be  able  to submit
 "comprehensive,  accurate and current emission inventories"  by  the  Act's
 January 1, 1979  deadline.  As an interim measure,  therefore, these States will
 have  to use emission estimates  to help  supplement their data base  until more
 reliable  emissions information  becomes  available.   For  traditional sources,
 EPA Document  AP-4232  and the 1976 TRC analysis of Emission  Rates For  Eighty
 Processes33 are "the  primary  references  recommended by EPA for  making  these
 estimates.  For  nontraditional  sources,  emission estimates  are less precise
 and reliance  upon EPA's  Guidelines  for  Development of Control  Strategies in
 Area  with Fugitive Dust  Problems is  required.3'*

      STEP 4 - Establishment  Of  Source/Air Quality Relationships

      Having defined  and  quantified  the  problem,  it becomes  necessary  to
 quantify  the  relationship between area  emissions  and  resultant ambient concen-
 trations.  Atmospheric diffusion models  are  employed  for  this  purpose.

      The  selection of an appropriate diffusion model  is a highly technical
 determination requiring  the  services of  trained professionals.   EPA has pub-
 lished numerous  guideline documents  on  atmospheric  modeling, the most recent
being its 1978 Guideline on Air  Quality Models.35   This guideline  specifies
 the models to be used in assessing control strategies for TSP  and  other cri-
 teria pollutants.  Approval of  the Regional EPA Administrator  is required
before other modeling approaches may be  employed.
                                      -30-

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     One of the major gaps in current air pollution knowledge concerns the
modeling of fugitive emissions and fugitive dust sources.  EPA's modeling
guidelines deal primarily with stack emissions.  Modeling techniques are
relatively well developed for stack emissions.  Due to the complex configura-
tion and emission characteristics of fugitive sources, however, traditional
modeling techniques are not adequate.  At the present time, therefore, model-
ing the impact of fugitive control strategies will be reviewed by EPA on a
case by case basis.  EPA is now studying alternative modeling techniques for
both fugitive process emissions and fugitive dust sources.  It is doubtful
that these studies will produce satisfactory fugitive modeling techniques in
the near future.

     STEP 5 - Evaluation Of Alternative Control Strategies

     The prior steps in the strategy development process lead naturally to
the evaluation of control alternatives.  The objective of this step is to
identify the most cost-effective means of ensuring timely attainment and
maintenance of the ambient standards.

     The first task in this assessment is to identify the sources (traditional
and/or nontraditional) which will receive priority attention for control.
Many considerations guide this determination, including economic costs,
administrative and social impacts, technological difficulties, and the air
quality benefits associated with imposition or tightening of controls on a
particular source.  A comprehensive analysis of these policy considerations
is beyond the scope of this paper.  Suffice it to say that this task forms
the cornerstone of the control strategy and should be treated accordingly by
State and local air quality strategists.  The ultimate objective is to achieve
the greatest level of emissions reduction over time at the lowest per capita
cost.  The selection of target sources sets the stage for realizing that
objective.

     Once the target sources have been identified, it becomes necessary  to
estimate the degree of emission reduction that will occur from full compli-
ance with adopted controls.  Such control measures may be in the form of
increased or expedited enforcement of existing regulations, or entirely new
regulations and programs.  These emissions reduction estimates comprise  the
key variable in the modeling exercise through which reasonable progress
toward timely NAAQS attainment is demonstrated.

     For existing sources, control strategies will have  to impose reasonably
available controls (RACT) to the extent necessary for NAAQS attainment.
This is particularly true for major industrial centers where traditional
stationary sources have not been subject to such controls under prior SIP's.
RACT may represent a relatively stringent level of control for these sources
and may involve forcing technological innovation.*  For  all sources, however,
     *Various efforts have either been completed or are underway to provide
guidance for determining RACT.  Technical support documents for new source per-
formance standards are a valuable information  source.  In addition, EPA is
currently in the process of issuing documents which describe RACT for numerous
particulate sources covering both stack and fugitive emissions.
                                      -31-

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 RACT will be determined on a case by case basis  taking  into account such
 factors  as  retrofit feasbillty,  economic and  energy  costs and environmental
 impacts.36

     In  urban areas where fugitive dust is causing high TSP levels, nontradi-
 tional source controls for reentrained dust,  construction activities, auto-
 motive particulates and secondary particulates will  have to be considered.
 While the impact of these sources are generally  localized in nature, they are
 typically found throughout a given area and may,  therefore, create widespread
 TSP violations.  The emission inventory should provide  the spatial segregation
 and emissions quantification necessary for evaluating these sources.

     Control of reentrained street dust is one of the most important nontra-
 ditional source programs which should be considered.  Unfortunately, it is
 also one of the most poorly understood particulate problems.  Field studies
 indicate that reentrained street dust consists primarily of sand and soil, and
 automotive  exhaust and debris from automotive wear and  tear of brakes, bear-
 ings and tires.  Findings from these studies  suggest two basic methods of
 control:37

     (1)  Reducing the amount of material being  deposited onto roadway sur-
          faces through curbing, gutter and sidew,alk improvements, enforcement
          of visible emission regulations for automotive vehicles, improve-
          ments in sanding operations for snow and ice  control and increased
          controls on street dust loadings from  construction vehicles.

     (2)  Street cleaning through sweeping and/or water flushing operations.
          Common sense would indicate that street cleaning should reduce re-
          entrained dust, but it is still unproven as an effective method for
          reducing ambient TSP concentrations.

     Urban roadway improvements anticipated in the next several years are
 expected to result in significant reductions  of re-entrained dust.  As older
vehicles are phased out and automotive particulate contributions decrease, TSP
 levels can be expected to decline in high traffic areas.  State or local
agencies seeking to accomplish additional control over re-entrained dust
 should refer to EPA's recent guideline document on Control of Re-entrained
Dust From Paved Streets.38  This guide provides more detailed information on
street cleaning, construction site control and the costs associated with these
 controls.  With respect to construction-related emissions, wetting or soil
 stabilization of exposed surfaces and access  roads appear to be the most
 feasible control alternatives.  Consideration should also be given to limiting
 the length of time that any cleared area may  remain  exposed before construc-
 tion activities commence.

     Another nontradltional control which will have  to be considered in some
areas concerns secondary particulates.  Although the relationships between the
precursors of secondary particulates (SO , NO  and organics)  are not well
understood,  it is suspected that these pollutants contribute from 5-15 pg/m3
of the particulate matter in many urban areas, much of it in the respirable
size range.39  To achieve the primary NAAQS for TSP, efforts will therefore
have to focus on controlling SOX, NO  and organic emissions so as to prevent
the formation of sulfate, nitrate and organic aerosal particulates.  While


                                      -32-

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additional understanding of aerosol formation is needed, urban TSP control
strategies should at least consider reduction of secondary particulate pre-
cursors as a possible alternative.

     STEP 6 - Analysis Of Estimated Air Quality Improvement

     Having identified alternative control strategies, the next step in the
process is to estimate the air quality impact of each alternative.  This is
accomplished through application of the atmospheric diffusion models already
selected under Step 4.  This model translates estimated emission reductions
over time into estimated resulting air quality.  Alternative strategies are
then manipulated until timely attainment of the ambient standards can be
demonstrated.

     STEP 7 - Adoption And Submittal

     The SIP Revision Memorandum, as noted earlier, distinguishes between
traditional and nontraditional source controls in terms of how they must be
addressed in the 1979 SIP submissions.  All necessary stack and fugitive
emission limitations for traditional sources must be adopted and submitted by
January 1, 1979.  Where nontraditional source control is part of the attain-
ment plan, however, formal regulations need not address them.  For these
sources the plan must instead contain:

     (1)  an assessment of the impact of nontraditional sources, and

     (2)  a commitment by the state to develop, submit and implement the
          appropriate procedures and programs.  Obviously, these schedules
          must include milestones for evaluating progress toward timely
          attainment of the standards.  Recognizing that the development of
          these programs will take considerable time, the memorandum advises
          states to initiate the necessary studies and demonstration projects
          for controlling nontraditional sources as soon as possible.

3.4  Conclusions and Recommendations

     Defining and evaluating control options for TSP nonattainment will
obviously take a great deal of study and effort.  The development of an
effective control strategy requires an accurate identification of the sources
of the problem, a quantification of emissions from those sources and an
understanding of the relationship between these emissions and air quality.
Once this information has been assembled, a control strategy can be developed
which reflects the relative contribution of traditional, nontraditional and
background sources to known NAAQS violations.

     Particulate control strategies have traditionally been oriented toward
fuel combustion, process emissions and incineration.  Control programs for
particulates have resulted in substantial emission reductions and resulting
air quality improvements in many urban areas.  Yet, further reduction in
these emissions can still be achieved.  Several specific recommendations were
made in the National Particulate Assessment, with regard to traditional
sources.  These included:
                                       -33-

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        o   Increased  regulatory  and  enforcement  attention  directed  to the
           primary metals and minerals  Industries;

        o   Increased  inspection,  source sampling and  enforcement activity to
           obtain compliance by  major sources with  existing regulations;

        o   Promulgation and enforcement of numerical  or visible "property-
           line" fugitive emission standards; operating and maintenance stan-
           dards for  specific processes such as  storage piles and material
           handling equipment; and increased paving of industrial roadways and
           parking areas;

        o   Increased  regulatory  attention to residential and commercial space
           heating boilers where they are shown  to  be a problem;

        o   Considerable tightening of emission limits for  fuel-burning instal-
           lations, especially oil-fired operations;

        o   Regulation of industrial  process emissions on an industry-specific
           basis.  Under existing regulatory practice, general process weight
           standards  are established for all processes, regardless  of how
           difficult  it is for any particular industry to meet them;

        o   Consideration of extending regulatory coverage  to smaller indus-
           trial point sources where the contribution of such sources to NAAQS
           violations is found to be significant.

     Even  with the traditional  control  measures  discussed above, it is appar-
ent that many urban areas will  not be  able to attain the ambient TSP stan-
dards before 1983.  This is the single  most important conclusion of the
National Particulate Assessment.  It presents difficult planning problems for
urban air  quality strategists since emission reduction efficiencies are lower
(and less  certain) for nontraditional  sources than for traditional sources.
The difficulties lie not so much in the technical  feasibility of nontradi-
tional  controls as in their cost and political  implications.

     Still, much can be done to control particulate  emission from automo-
biles, and construction activities and  from re-entrainment of particulates
from urban streets.

     Finally, it is important to remember that  there are a number of gaps in
current data and understanding which will have  to  be overcome before TSP
control strategies can be evaluated with the degree  of precision necessary.
Two of  the most critical areas of needed investigation are siting criteria
for TSP monitors and the relationship between meteorology/climatology/topog-
raphy and ambient TSP concentrations.   Improved emissions/air quality data
bases and expanded research into techniques for modeling and controlling
fugitive emissions and fugitive dust will also be  Important to the control
effort.
                                     -34-

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                                   FOOTNOTES






1.   Clean Air Act (hereafter "CAA") §109.




2.   40 CFR 50.




3.   A3 FR 46246.




4.   CAA §110(a)(2)(A).




5.   40 CFR §51.13 and 51.18.




•6.   41 FR 55524.




7.   CAA §110(a)(2)(I).




8.   Sierra Club vs. Ruckelshaus, 4 ERG 1205.




9.   CAA, Subchapter I, Part C, Subpart 1.




10.  CAA §162.




11.  CAA §162.




12.  CAA §165  and  §169(1).




13.  CAA §165(a)(4) and §169(3).




14.  CAA §165(c).




15.  CAA §166.




16.  42 FR 57459.




17.  43 FR 26380,  40 CFR  51.24, 52.21.




18.  40 CFR 52.21(b)(b).




19.  43 FR 26395.




20.  Id.




21.  43 FR 8962.




22.  CAA  §107(d)(5).




23.  43 FR 8963.




24.  Id.






                                      -35-

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25.  43 FR 21676.

26.  Id.

27.  EPA-450/3-76-025, p. 30.

28.  Id. at p. 78.

29.  Id. at p. 70.

30.  43 FR 46247.

31.  EPA Guideline for Development of Control Strategies in Areas With
     Fugitive Dust Problems, EPA-450/2-77-029 at p. 3-10.

32.  This document establishes emissions factors for many air pollution
     sources.

33.  EPA Contract Report No. 68-02-1382 T.O. #12.

34.  Supra, note 31.

35.  EPA-450/2-78/027, May 1978.

36.  December 9, 1976 EPA memorandum from Roger Strelow to EPA Regional
     Administrators.

37.  Supra, note 27 at pi 128.

38.  EPA-907/9-77-007.

39.  Supra, note 27 at p. 48.
                                     -36-

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THE IMPACT OF FUGITIVE EMISSIONS ON

TSP CONCENTRATIONS IN URBAN AREAS
           Prepared By

         Ronald G. Draftz

      IIT Research Institute
       10 West 35th Street
        Chicago, IL  60616
                -37-

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                                ABSTRACT*
         The primary  cause  of  total suspended  particulate  (TSP) violations
 in urban areas  such  as  Chicago,  Phoenix,  Philadelphia,  St.  Louis, Miami,
 Denver  and many others,  is due to  fugitive  emissions.   These  fugitive
 emissions, contributing from  40% to 70% of  the  TSP  concentrations,  are
 principally from a single  source - suspension of  roadway  dust and pavement
 aggregate by vehicles.   This  roadway dust is  mainly pavement  aggregate
 but also includes rubber tire fragments and other deposited dusts such as
 soil minerals.   The  contributions  from various  entrainment  mechanisms such
 as direct tire  erosion  or  tire and vehicle  turbulence is  unknown but have
 a direct impact  on control strategies.

         Microscopical analysis supplemented with  chemical analysis has
 proven  to be the most useful  method of determining  the  sources of fugitive
 emissions.  This analytical protocol will be  described  in detail along
 with the techniques  for  source assignments.
* This paper was not available at the time of the Proceedings' publication.
                                 -38-

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EMISSIONS AND EFFLUENTS FROM COAL STORAGE PILES

                      by

                T. R. Blackwood
                      and
                 R. A. Wachter
         MONSANTO RESEARCH CORPORATION
               DAYTON LABORATORY
             Station B, P.O. Box 8
              DAYTON, OHIO  45407
                     -39-

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ABSTRACT

Coal  storage piles are  sources  of atmospheric  emissions of  fugitive dust and
nonpoint  effluent discharges.

Pile  geometry, coal erodability (dustiness), wind, humidity, precipitation and
temperature are the major parameters known  to  contribute  to the emissions from
coal  storage piles.  From the literature and a source-oriented sampling pro-
gram, an  equation was derived describing the mass emission  rate from a given
coal  pile.  This program also showed that the  variability of the emissions
from  a specific coal pile are much greater  than that between piles.  This is
due to the large influence that wind speed  and the precipitation-evaporation
index have on emissions.  Emissions were analyzed utilizing x-ray fluorescence
and atomic absorption.  Particle size analyses were conducted on two samples.
Over  97 percent of the particles, by number, were smaller than 10 microns.
Eighty-eight percent of the particles from  a composite Brink® sampler taken
over  two  days of sampling were  smaller than 5  microns in  size.

The water pollution potential of coal stockpiles maintained outdoors at pro-
duction and user sites was also studied.  These storage piles are sources of
effluents due to the drainage and runoff of wastewater which occurs during
and after precipitation.  The runoff usually flows from the drainage area into
the nearest waterway.  In this  study, the effluent levels from these sources
were quantified by examining coals (both freshly mined and  aged)  from six coal
regions of the United States.  Coals were placed under a rainfall simulator
and grab samples of the drainage were collected.  The samples were analyzed
for organic and inorganic substances and for water quality  indicators.

The coal leachate and air samples were also analyzed for selected polycyclic
organic materials, and only small quantities of POM's were  detected.
                                    -40-

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INTRODUCTION

Water effluents and air emissions exist at coal stockpiles maintained outdoors.
Water effluents form from the drainage and runoff of wastewater which occurs
during and after precipitation.  Air emissions form from the action of wind
forces on the exposed coal surface.

Effluents were evaluated from six major coal regions of the United States (1).
Data were obtained by placing several coals beneath a rainfall simulator and
collecting integrated samples of the drainage.  The samples were analyzed for
chemical compositions and water quality indicators.  Hydrologic relationships
were used to estimate the runoff concentrations of full size stockpiles from
the simulator concentrations.

Emissions were evaluated using field sampling of typical stockpiles and wind
tunnel studies of the erosion process (2).  Air emissions were analyzed for
chemical composition and air quality indicators.

SOURCE DESCRIPTION

Three-fourths of all coal produced is consumed at electric utilities.  In
1975 there were approximately 950 coal stockpiles containing 124 x 106 metric
tons of coal at user facilities throughout the United States.  These stock
piles are maintained outdoors and exposed to a variety of atmospheric condi-
tions.  Rainfall leaches pollutants from the stockpile which drain into
waterways.  Aquatic life forms in the waterways are thus exposed to the
pollutants.  Drainage in coal mining operations produces high sulfate concen-
trations and low pH values in nearby streams.  Hence, the potential for this
same problem exists at coal stockpiles because pyrites, the prime factor in
acid mine drainage, exist within the coal pile.

Wind blows the loose and fine coal away from the stockpile.  The combined
leaching and drying of the coal causes fracturing which releases more fine
material that can become airborne.  Mechanical movement of the stockpile
during usage also releases or fractures more coal.

In addition, coal contains inorganic substances in the "ash"  (extraneous
mineral matter) and in the coal structure; these substances are released.
Because coal is primarily organic, organic contaminants are also released.

AIR EMISSIONS

Carbon monoxide  (CO) hydrocarbons and particulate matter are the criteria
pollutants emitted.  Concentrations of carbon monoxide and hydrocarbons
are barely detectable  (<20 ppm CO, and <5 ppm hydrocarbons); these can be
expected to be three orders of magnitude below ambient air quality criteria
at a distance of 50 meters from the pile.  The average emission factor for
respirable particulates  (those smaller than  seven microns in diameter) is
6.4 milligrams/kilogram of coal per year.  The composition of the emissions
from coal piles is essentially that of coal  dust.  There is no significant
increase in the level of any known hazardous species other than the normal
increase found when coal is fractured to produce dust.  This increase is
shown in Table 1.
                                     -41-

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                   TABLE 1.  COMPOSITION OP COAL AND COAL DUST


                           Amount in coal,   Amount in coal dust,
                Element         ppm 	 	ppm
Arsenic
Cadmium
Copper
Iron
Nickel
Vanadium
0.3
0.2
25
1,600
2.7
12
26
3.8
868
79,200
755
166
 Pile geometry,  coal erodability (dustiness),  wind, humidity, precipitation
 and temperature are the major factors known to contribute to the emissions
 from coal storage piles.  Coal erosion has been studied in a wind tunnel,  and
 the effects of  most of these factors, or their equivalents, have been
 evaluated.   Equation 1 describes the mass emission rate from a given coal
 pile in terms of these factors.

                                      U3p 2S0.345
                            Q = (336)	                           (1)
                                         (P-E)2


                        Q = emission rate,  mg/s
                        u = wind  speed,  m/s

                       pb = coal  density, g/m3

                        s = surface  area, m2

                    (P-E) = precipitation-evaporation  index

 During  this study,  variability of the emissions from  a specific coal pile  were
 determined  to be much greater than  the variation of emissions from one  coal
 pile to another.   This is  due to the large influence  that wind speed and
 precipitation-evaporation  rate have on emissions.   The location of a specific
 coal pile will  have a major influence on the  emission rate.  One storage
 pile sampled  one day apart showed emission rates of 14 and 41 milligrams per
 second.   The  emission rate may also be  essentially zero,  as it was during  some
 days of the sampling program.  One  of three sampling  tests showed undetectable
 contributions due  to the storage pile.

Because about 90 percent of the  coal  stored in  the United  States  is  stored in
P-E  index regions of 90 to  130 (Figure  1), the  effect  of the  P-E  index  is
reduced substantially  for the average coal pile.   In addition, the distribution
of coal piles shows  that a  tremendous quanity of small piles  exist.  The most
frequently occurring coal pile size is  49,000 metric tons;  the average  size is
95,000 metric tons  (Figure  2).
                                      -42-

-------
27.2

K.t

25.6

21.1

20.0

II.
       I '2'7
       S 10.»
          7.2
                                           01.061
                                        127.27
                                                   PCRCCNIAGES ARf SHOWN IN 1 1
                                               I23.Z9I
                                                  16.161
              10  »   30  40  50  60  70  W 40 100  110  120  1» 140 150 160  170  110
                                       P-C INDEX

Figure 1.   Quantity of  coal stored as  a  function of P-E index.
                                           MEAN = 95,000 metric tons
                                           MODE=49,000 metric tons
                      200     400     600     800    1,000   1,200    1,400

                            SIZE OF COAL PILES. 103 metric tons


        Figure 2.   Distribution of coal  storage  pile sizes.
                                      -43-

-------
A coal  storage pile of  112,000 metric  tons was  sampled  at  two  seasons of the
year:   late March and mid-August.  Only  small variations in  the  emissions
were observed between these two  sampling sets.   The average  emission factor
was 6.4 milligrams per  kilogram  of coal  per year;  the estimated  population
standard deviation was  2.9 milligrams  per kilogram of coal per year.  The
emissions were analyzed utilizing x-ray  fluorescence and atomic  absorption;
their compositions were essentially  that of coal dust.  Particle size analyses
were conducted on two samples.   Over 97  percent  of the  particles, by number,
were smaller than 10 microns.  Eighty-eight percent of  the particles from a
composite Brink® sampler taken over  two  days of  sampling were  smaller than
5 microns in size.  Based upon these results, it is concluded  that essentially
all of  the emissions are in the  respirable range.  No fibers were detected in
any of  the samples.  The coal samples  were also  extracted  with pentane and
analyzed for selected polycyclic organic materials using chemical ionization
mass spectroscopy.  Although small quantities (<0.5 ppm) of  benzo(c)phenan-
threne, benzo(a)pyrene  and 3-methylcholanthrene  were detected, the quantity
identified was insignificant compared  to the quantity of coal  dust.

In order to evaluate the impact  of coal  storage  on the  environment, a repre-
sentative coal pile was defined  from average parameters.   This representative
stockpile would contain 95,000 metric  tons of bituminous coal piled to an
average height of 5.8 meters.  The pile  would be located in  a  P-E region of
91, be  exposed to an average annual  wind speed of  4.5 meters per second, and
be located 86 meters from the nearest  plant boundary.   Assuming  that this coal
pile is round, Figure 3 shows the approximate relationship between the coal
pile, the plant boundary and a typical emissions radius.   The ambient concen-
tration of particulate at different  distances is given  in  Table  2 based on a
particulate emission rate of 19 milligrams per second or 610 kilograms per
year from the average pile.  These ground level  concentrations were calculated
using dispersion methodology as described by Turner (3).   The coal pile which
was sampled in this study had parameters very similar to those of the repre-
sentative stockpile.
               TABLE 2.   AMBIENT CONCENTRATIONS  OF PARTICULATE
              Distance from
               coal pile,
Ground level concentration, yg/m3
   Instant	24-hr average
                   86
                  528
     18
      1.9
6.4
0.67
                  Figure 3.  Emissions radius of coal pile

                                    -44-

-------
WATER EFFLUENTS

Because coal is a complex aggregate capable of discharging a vast range of
compounds, the study (1) was limited to compounds listed on the EPA Toxic
Substances List (4), pollutants with effluent limitations for coal storage
areas, and other water quality criteria used to indicate the presence of
classes of compounds.  Due to the diversity of stockpiles and coals, several
samples were collected from each of the six major coal regions of the United
States.  Aged coals and fresh coals were collected.  Samples were selected to
represent the range of inorganic element content in coal and to obtain coals
that were representative of each coal region.

The apparatus shown in Figure 4 was used to simulate rainfall of representative
intensity and duration.  Coal samples were placed under this apparatus for
exposure to simulated rainfall.  Drainage seeped through the coal, out the
bottom of the pans, and into collection bottles.  A background sample was also
obtained of the rainfall water used.  Three simulation runs were completed
over a period of 30 days.  The time between runs was varied to observe its
effect.  The average effluent concentration found for each coal region is
presented in Table 3.

The effluent levels from a representative stock pile were computed as coal-
production-per-region weighted averages.  Table 4 presents these levels at
the source.  However, the pollutant concentration levels in the stream that
enters the nearest waterway result from the dilution of pile drainage by runoff
waters in the entire coal storage area.

The representative storage pile was assumed to be located 86 meters from the
receiving waterway.  The representative rainfall rate is 0.7 centimeter per
hour over a stockpile area of 18,792 square meters.  This rainfall occurs
139 days per year  (i.e., every 2.6 days) and lasts for'approximately one hour.
However, only 15 percent of the rainfall volume on the pile appears as direct
runoff used in the rational method of hydrology  (5).  Volumetric flow  from
the pile was computed as 21 cubic meters per hour.

Runoff from the entire coal storage area was obtained from a survey of coal
storage sites; the average runoff was 610 cubic meters per hour  (6).

The concentration levels shown in Table 4 are diluted by the drainage area
volumetric flow to obtain the effluent concentrations shown in Table 5.
Thorough mixing of runoff waters with pile drainage is assumed.  The coal
aggregate retards the runoff flow for a time period sufficient to enable
mixing of upstream runoff.

CONCLUSION

Pollution from coal stockpiles is a site-specific problem.  Large, aged coal
stockpiles located in areas of frequent and  light rainfall will generate much
higher effluent concentrations than that of  the representative pile used in
this study.  The variability of the emissions is also dependent on the site,
although local meterology will be the dominating factor.  Air emissions will
not be a major problem because of the small  contribution to ambient air quality
at typical exposure distances, even for coal stockpiles of several million tons.
Water effluents from Interior Western  (Iowa  to Texas and Arkansas to Nebraska)
and possibly the Great Northern Plains  (Montana, North and South Dakota) could

                                      -45-

-------
          DISTILLED WATER
                   Figure 4.  Rainfall simulation apparatus.
  TABLE 3.  AVERAGE EFFLUENT DRAINAGE CONCENTRATION FOR EACH COAL REGION
Effluent concentration, g/m3
Effluent parameter
Total suspended solids
Total dissolved solids
Sulfate
Iron
Manganese
Free silica
Cyanide
BOD5
COD
Nitrate
Total phosphate
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Selenium
Silver
Zinc
Mercury
Thallium
pHb
Chloride
Total organic carbon
Appalachian
1,521
259
66
3.1
0.03
12.3
<0.001
<5.0
1,407
0.12
NDL
2.1
23
NDL
NDL
NDL
0.02
0.05
0.06
23.8
NDL
0.008
<0.001
NDL
6.28
0.33
251.7
Great
Northern
Plains
1,282
430
1,598
1.5
0.14
NDLa
NDL
<7.5
1,324
0.14
NDL
NDL
1.8
HDL
NDL
NDL
NDL
0.05
0.02
NDL
NDL
0.17
0.003
NDL
6.93
NDL
373.2
Interior
Eastern
1,264
1,136
648
9.1
0.44
0.8
0.002
NDL
1,556
0.33
NDL
7.5
4.1
NDL
NDL
NDL
NDL
0.06
0.09
12.5
NDL
0.14
NDL
NDL
7.62
NDL
380.1
Interior
Western
1,853
5,539
4,860
1,131
17.9
86.3
NDL
<1.2
1,053
0.09
NDL
10.3
10.1
NDL
0.05
0.03
2.2
0.33
10.2
25.2
NDL
25.0
0.004
NDL
2.81
2.3
90.5
Western
2,486
1,900
240
8.2
0.4
NDL
NDL
<2.5
1,826
1.8
NDL
14.0
5.6
NDL
0.005
0.04
NDL
0.07
0.05
15.0
NDL
0.15
0.005
NDL
7.24
NDL
318.4
Southwestern
1,538
356
190
5.5
0.04
NDL
NDL
<7.5
769
0.16
NDL
6.5
4.1
NDL
NDL
NDL
0.02
0.05
0.03
21.5
NDL
0.04
0.002
NDL
6.60
NDL
158.7
3No detectable level.   Negative logarithm of hydrogen ion concentration.
                                       -46-

-------
  TABLE 4.   COAL PRODUCTION-WEIGHTED

            EFFLUENT CONCENTRATION
                        Concentration,

  Effluent parameter	g/m3
Total suspended solids
Total dissolved solids
Sulfate
Iron
Manganese
Free silica
Cyanide
BOD5
COD
Nitrate
Total phosphate
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Selenium
Silver
Zinc
Mercury
Thallium
pH
Chloride
Total organic carbon
1,551
754
401
39
0.69
10.1
<0.001
<3.8
1,436
0.31
NDL3
4.6
15.7
NDL
0.002
0.004
0.08
0.06
3.1
19.9
NDL
0.80
<0.001
NDL L
6.78
0.27
280
a
 No detectable level.
b
 Negative logarithm of hydrogen

 ion concentration.
                   -47-

-------
TABLE 5.  CALCULATED RUNOFF CONCENTRATIONS FROM
          THE REPRESENTATIVE COAL STORAGE FILE
                            Concentration
                         entering waterways,
   Effluent parameter	g/m3	

 Total suspended solids          7.8
 Total dissolved solids          3.8
 Sulfate                         2.0
 Iron                            0.2
 Manganese                   3.4 x 10"1*
 Free silica                     0.05
 Cyanide                      <5 x 10~6
 Nitrate                     1.5 x 10~3
 Total phosphate                 NDLa
 Antimony                        0.02
 Arsenic                         0.08
 Beryllium                       NDL
 Cadmium                       1 x 10~5
 Chromium                      2 x 10~5
 Copper                        4 x 10~5
 Lead                          3 x I0~k
 Nickel                          0.02
 Selenium                        0.1
 Silver                          NDL
 Zinc                          4 x lO'4
 Mercury                       5 x 10~6
 Thallium                        NDL
 Chloride                    1.3 x 10~3
 Total organic  carbon            1.4
 2-Chloronapthalene             7 x 10~5
 Acenapthene                    7 x 10~5
 Fluorene                      7 x 10~5
 Fluoranthene                   8 x 10~5
 Benzidine                      7 x 10~5
 Benzo(ghi)perylene             2 x 10~^

 a                                 ~   ~~~  ~   ~
 No  detectable level.
                      -48-

-------
present a major effluent problem which would require neutralization and sedi-
mentation of the runoff (primarily for control of acid).

ACKNOWLEDGMENT

This research was funded by the Industrial Environmental Research Laboratory
of the U.S. Environmental Protection Agency, Cincinnati, Ohio, under contract
68-02-1874.  The content of this paper does not necessarily reflect the views
or policies of the U.S. EPA.  The authors are indebted to Dr. Lawrence Huggins
and the Agricultural Engineering Department of Purdue University for their
assistance in this research.  This acknowledgment does not convey an endorse-
ment by Purdue University of the research results.

REFERENCES

1.  Wachter, R. A. and T. R. Blackwood.  Source Assessment: Water Pollutants
    from Coal Storage Areas, EPA-600/2-78-004m, U.S. Environmental Protection
    Agency, Cincinnati, Ohio, May 1978.  123 pp.

2.  Blackwood, T. R. and R. A. Wachter.  Source Assessment: Coal Storage Piles.
    EPA-600/2-78-004k, U.S. Environmental Protection Agency, Cincinnati, Ohio,
    May 1978.  98 pp.

3.  Turner, D. B.  Workbook of Atmospheric Dispersion Estimates.  Public Health
    Service Publication No. 999-AP-26, U.S. Department of Health, Education,
    and Welfare, Cincinnati, Ohio, May 1970.  84 pp.

4.  Sampling and Analysis Procedures for Survey of Industrial Effluents for
    Priority Pollutants.  U.S. Environmental Protection Agency, Cincinnati,
    Ohio, March 1977.  180 pp.

5.  Handbook of Water Resources and Pollution Control.  H. W. Gehm and
    J. I. Bregman, eds. Van Nostrand Publishing Company, New York, New York,
    1976.  pp. 444-447.

6.  Development Document for Proposed Effluent Limitation Guidelines and
    New Source Performance Standards for the Steam Electric Power Generating
    Point Source Category.  EPA-440/1-73-029, U.S. Environmental Protection
    Agency, Washington, D.C., March 1974.  pp. 128-130.
                                       -49-

-------
URANIUM MILL TAILINGS AREA

     FUGITIVE EMISSION



             BY



    P. G. Complin, P.Eng.

            and

         P. Piersol



             of
 JAMES F. MacLAREN LIMITED
 435 McNicoll Avenue
 Willowdale, Ontario
 M2H 2R8
             -51-

-------
          ABSTRACT FOR THE THIRD SYMPOSIUM ON FUGITIVE EMISSIONS;
                         MEASUREMENT AND CONTROL
              Uranium Mill Tailings Area Fugitive Emissions
For the past year and a half, an environmental assessment of the expansion
of Canada's largest uranium mining area has been underway.  Investigation
of the air quality aspects has involved an extensive study of tailings
area fugitive dust emissions by field monitoring and emission and dispersion
modelling.

The hi-vol field program resulted in approximately 500 samples of 24-hour
suspended particulate concentrations at locations in the immediate
vicinity of seven tailings areas.  Micrometeorological stations located
on the tailings areas, provided wind speeds, wind directions, rainfall and
other meteorological data at the source during some of the dust sampling
periods.  There were very large day to day changes in suspended particulate
levels next to tailings areas.  The majority of the readings obtained were
less than 60 ng/m3 with an occasional value above 1000 yg/m3 and a number
of values below 20 yg/m3.  It was ascertained that suspended particulate
levels are highly dependent on tailings moisture content and surface
windspeed.

A computer model for the emissions and dispersion of dust from the tailings
areas was developed based on the concepts of particle saltation, suspension,
and deposition and atmospheric transport using a Gaussan tilted plume model.
The selection of a suspension factor of 10"7 per meter resulted in good
agreement between the model and the field program results.  The ratio
of suspended particulate concentrations calculated from the tailings
to actual measured suspended particulate ranged from 0.07 to 2.91, with
an average ratio of 1.1.
                                   -52-

-------
               URANIUM MILL TAILINGS AREA FUGITIVE EMISSIONS
Since the fall of 1976, an environmental assessment of the expansion of
Canada's largest uranium mining area has been underway.  Investigation of
the air quality aspects has involved an extensive study of tailings area
fugitive dust emissions by field monitoring and emission and dispersion
modelling, with the intent of predicting the potential impact of tailings
emissions after mine expansions.

In Elliot Lake region of Canada, underground mining of uranium deposits in
quartz-pebble conglomerates has been conducted since the 1950's and is expec-
ted to continue until the turn of the century.  In underground mining, the
ore is drilled, blasted, transported to underground primary crushing,
hoisted to the surface, crushed again and conveyed to the mill for uranium
extraction.  A "typical" mill illustrated in the schematic shown  (Fig. 1)
consists of ten primary steps:
                      Ore Crushing
                      Ore Grinding
                      Leaching
                      Solid/Liquid .Separation
                      Solution Upgrading
                      Uranium Precipitation
                      Uranium Thickening/Filtration
                      Drying
                      Packaging
                      Tailings Treatment/Discharge

After tailings neutralization, the tailings slurry is disposed of in contain-
ment areas.  Within the Elliot Lake region, the tailings areas are usually
natural basins often containing swamps and small lakes with waste rock used
for containment dams.  The uranium mining industry has been active in this
area since the 1950's and there are presently both active and inactive mines
and mills.  There are a total of seven majcr tailings  areas of which two are
                                     -53-

-------
                               ft n ftf
                       ORE RECEIVED
                         AT MILL
                                          MILL
                       ORE CRUSHING
                       ORE GRINDING
 SOLUTION
UPGRADING
                       LEACHING
                     SOLID/LIQUID SEPARATION
                                TAILINGS
                              NEUTRALIZATION
    URANIUM
  PRECIPITATION
                Solution
                Decoding
                Rtogcnts
                       URANIUM THICKENING/
                         FILTRATION
                  DRYING
                 V
                   LLMJt
PACNNG,
      'SHIPPING
                                                                  Underground
                                                          PRIMARY FLOWS

                                                          TAILINGS STREAMS

                                                          SECONDARY FLOWS
                               TAILINGS   SETTLING
                                       BASIN
                                                                        f
                                                                 PRECIPITATION
                                                                   BASIN
                                                         Troottd
                                                         Efflutnt
                                                         Oitehorg*
                             Uranium  Mill  Process

                                   Schematic
                                                                            FIG. I

-------
now active and five inactive.

Very little information is presently available about windblown particulate
from tailings areas.  Dust emissions from tailings areas share many simi-
larities with the common fugitive sources such as unpaved roads, agricultural
tilling operations, aggregate storage piles and heavy construction operations.

To gain more information, a field programme of measuring suspended particulate
and dustfall was undertaken in the immediate vicinity of the tailings areas.
Suspended particulate was collected with high-volume samplers and particulate
deposition was collected in dustfall jars.  One hi-vol sampler and one dust-
fall jar constituted a sampling station.

Wind data for the region showed that although no wind direction predominates,
north and west winds were expected to occur most frequently.  Consequently,
upwind-downwind sampling was used in assessing the tailings dust emissions.
In addition to the hi-vol samplers, micro-meteorological stations were
located directly on the tailings areas to obtain data on conditions which
'affect the wind generation of the dust.

This approach was modified to account for topographic constraints, access to
sites and the proximity of interferring  sources such as roads and construc-
tion.  Within these general  siting criteria, the precise locations for the
sampling stations were chosen in areas generally clear of dense bush with a
visible line of sight between the tailings and the sampling  station.  If
locations were in close proximity to roads, calcium chloride solution was
used to limit road dust generation.

There were very large day-to-day changes in suspended particulate  levels
next to the  tailings areas.  The majority of the  readings were  less than
60 yg/m3 with an occasional  value above  1000 yg/m3 and a number of values
below 20 yg/m3.  A  summary of the results is presented  in Table 1.

Further interpretation of the data  confirmed  some beliefs on the affect
of wind, rain and  snow-cover on the degree of  dust generated.   Figure  2
illustrates  the results  from a  portion of the  1977  summer particulate

                                     -55-

-------
                                                      TABLE  1
I
Ln
      Tailings
      Monitoring
      Site
Stanrock 1
         2
         3

Long Lake I
          2
          3

Nordic 1
       Lab

Crotch Lake 1
            2
            3

Panel 1
      2

Quirke 1
       2
       3

Number
of
Readings
31
30
29
13
13
15
73
66
38
35
9
5
2
48
28
8
SUMMARY
Distance
To Dry
Tailings
(m)
100
100
250
60
60
1000
100
200
20
20
60
10
20
120
30
1000
OF TAILINGS
Average
of
Readings
(yg/m3)
115
91
22
44
15
38
94
24
54
43
15
10
44
43
48
67
SUSPENDED
Geometric
Mean of
Readings
(yg/m3)
45
55
19
26
13
19
32
20
27
22
13
7
30
33
23
43
PARTICULATE

Highest
Reading
(yg/m3)
1051
575
60
240
49
262
1965
65
341
300
34
24
75
147
441
276
SURVEY

Lowest
Reading
(yg/m3)
14
9
6
4
6
1
0
4
4
4
5
1
12
7
1
16
% of Readings
Above 120
yg/m3
(%)
16
17
0
8
0
7
10
0
13
9
0
0
0
2
7
13
                                                                                                 % of Readings
                                                                                                 Above  400
                                                                                                  yg/m3
                                                                          6
                                                                          7
                                                                          0

                                                                          0
                                                                          0
                                                                          0

                                                                          5
                                                                          0

                                                                          0
                                                                          0
                                                                          0

                                                                          0
                                                                          0

                                                                          0
                                                                          4
                                                                          0
      Sheriff Lake
                  61
1000
21
18
48

-------
EFFECTS OF WIND AND RAIN
ON  SUSPENDED PARTICULATE
                    FIG  2

B R ;

H
wind vanes p



y






tailtngs
wet
tailmgs drying pi n
fvt m N












-c.t6 .- •' . •• &
ifttfl
10 ' ' '
JUNE

•





-


r r '*<•
*T °t*
1 ' 15 ' '
h
[
I
1
gh
' ! M
I

If



1 S i




-

lr


llL
1 20 ' ' ' r '

]

|








/\


°'s^f
1965

-i






r
r
21 ' '
JULY
r4'
LO
pit
-9
>


WIND











high


[
25
VEL
!

J

i

fliS
-

h


I i I I

: a B i i

• . wet • 	 «L
i 1




ow
30
OCITY (km/hr)
v max
V
• average
RAINFALL (mm)



TAILINGS
MOISTURE
>V^



1
1
LvJtr
n ii
AUGUST
-100
-50
-10


40
20
0
10
15
0

100
50
5 ' ' ' '
STATION 1
r STATION 2
TIME (days)
SUSPENDED PARTICULATES
(Concentration pg/m3 )
NOTE : lOng/m3 is limil o( detection
    -57-

-------
 survey  selected  to demonstrate  the  effects of  tailings moisture content and
 windspeed on  suspended particulate  levels.  Between June  12 and June 16, the
 tailings were drying out following  rain and the  suspended dust levels rose
 quite steadily day by day  from  20 to 70 Ug/m3  at Station  1 and from 13 to 62
 yg/m3 at Station 2.  During this time wind speeds averaged about  6 kra/h
 (4 mi./h).  The  rainfall on June 16, 17 and 18 caused dust levels to drop to
 0 at Station  1 and 13 and  Station 2 by June 18,  even though the wind speeds
 over this period were higher.

 The role of high wind speeds is clearly shown  by the July 25 data.  On July
 25, average winds of 18 km/h  (11 mi.A) with gusts to 30  km/h  (19 mi./h)
 combined with dry tailings resulted in the highest dust level recorded at
 Station 2.  However, on July 31, comparable wind gusts and only a slightly
 lower average wind speed showed low dust levels  due to an increase in tailings
 moisture content.

 The principle survey was conducted  during the  summer of 1977 and a lesser
 continuing programme is still underway.  Annual  data, Table 2, indicates the
 effects of seasonal climatic changes on airborne dust released from tailings
 areas.  The geometric means and highest values recorded during the winter
 months are very  low.  During the spring period,  the values increase somewhat,
 but it is obvious from the data that summer conditions result in higher
 values.  Clearly, the tailings are  not prone to  becoming  airborne during the
 winter months, and are less likely  to drift in the spring than summer.

 Sufficient data was available from  two active  tailings areas to perform a
 upwind-downwind  analysis.  The results do confirm the belief that tailings
 dust is carried  downwind and will result in elevated suspended particulate
 levels immediately adjacent to the  tailings area.  They do not, however,
 identify the effect of tailings fugitive emissions on the areas of concern,
 the townsites and residential areas.

For this reason,  a theoretical model,  based on sand physics,  was used to
predict air emissions, and classical atmospheric dispersion techniques were
used to transport and deposit the airborne particulate.  The results of the
monitoring program were used to calibrate the model.

                                     -58-

-------
             TABLE 2
SEASONAL SUSPENDED PARTICULATE RESULTS
     JUNE 1977 - AUGUST 1977

MONITORING
SITE
NORDIC 1
NORDIC LAB
NUMBER
OF
READINGS
73
66

AVERAGE
(ug/m3)
94
24
GEOMETRIC
MEAN
(yg/ta3 )
32
20
HIGHEST
READING
(ug/m3 )
1965
65
    NOVEMBER 1977 - MARCH 1978
NORDIC 1
NORDIC LAB
45
44
13
13
6
10
81
33
      APRIL 1978 - JUNE 1978
NORDIC 1
NORDIC LAB
27
28
35
31
21
20
236
106
                -59-

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The air pollution effect of fugitive emission sources depends on the quantity
and drift potential of the dust particles entrained into the air.  In addition
to large particles which tend to settle out near the source, fine particles
can be entrained and will disperse from the source.

Studies on sand movement and desert dunes have shown that the transport of
materials similar to tailings is affected by particle size distribution, local
wind velocities  (including wind gusts), and other variables.  Exposed surface
area and the physical condition of the tailings also have a pronounced effect
on dust entrainment.

As part of the overall programme to expand the data base for parameters which
affect tailings emi-sions and provide information for the model exposed
tailings areas were examined and a series of tailings particle size analyses
were initiated.

Aerial photographs and field observations were combined in an effort to
delineate the extent of wet and dry tailings and develop the dry exposed
surface areas.  Size sampling programmes were undertaken at two non-operating
tailings areas and at two operating areas.  Samples were taken from tailings
areas which differed in terms of texture and appearance, and these samples
were aggregated and dried prior to sizing analysis.

A model for dispersion of dust from a uranium mill tailings area was developed
by James F.  MacLaren Limited for use at the Elliot Lake properties.  The model
is based on a concept developed by the Oak Ridge National Laboratory and
includes particle saltation, suspension and deposition and atmospheric trans-
port using a Gaussian plume model.

The suspension of dust at the source is related to the process of saltation
as described by Bagnold and an emplirical estimate 'of the particles which
remain airborne near the tailings surface, referred to as suspension.

The saltation rate equation presented here is influenced by the windspeed,
V, and the theshold wind velocity,  Vt,  required to initiate particle motion.
                                      -60-

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                                  TABLE 3
                    TAILINGS PARTICLE SIZE DISTRIBUTIONS
PARTICLE
  SIZE
   TYLER
  SCREENS
FOR SAMPLES
PREDOMINANT
 EMISSION
PROPERTIES
PREDOMINANT
DISPERSION
PROPERTIES
   ym
                    mesh
                                          t
300-150 to 100 CREEP
AND
150-106 100 to 150 SALTATION
106-80 )
) 150 to 200
80-75 ) J
75-44 )
) 200 to 400 SUSPI
44-38 )
<38 <400


3NSION

f
                                            I
                                                           DUSTFALL
                                                          SUSPENDED
                                                          PARTICULATE
                                      -61-

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 Saltation  Rate,  q
The material remaining  in suspension per  unit area,  S, has been  shown  to be
direct function of the  saltation rate:

     Suspension, S = kq
where  the value of K, the  suspension factor, varies  from  10   to  10   per
metre  dpending upon the particle  size and mass.

The dust emission rate or  source  strength is the material remaining in sus-
pension per unit area multiplied  by the  source area:

     Emission rate, Q = SA

The dispersion and deposition of  the suspended materials  was based on the
"titled plume" method described by Pasquill:

     X (x,0,0) =     2i       exp / - (H- v    * x/
                  2 7T 6 6  u            	-j7	
                       y z       \       26z
This equation assumes that material reaching the ground will not be reflected
or entrained.  Some percentage of smaller particles will  be reflected at the
ground and so this equation overestimates deposition and  underestimates
suspended particulate concentrations.

To ensure that the model predictions resulted in conservative values for
both deposition and suspension for small particles separate models were used
to calculate suspended particulate and deposition.

The previous equation was used to model deposition and modified for suspended
particulate as follows:

     X (x,0,0) -   Qi        exp/- (H-v  '  x/u)2 \ + exp / - (H-v  ' x/u)2
                 2 TT 6 6 u      '       S
                                       26^
                                         z
                                     -62-

-------
The principal difficulty in using the nodal to quantify tailings dust
emissions and dispersion is the selection of the suspension factor,  K.   As
noted, K values can range from 10~5 to 10~9 per metre,-which covers  a ten
thousand fold variation.

Value of 10~7 per metre was compared with the arithmetic average values for
the tailings hi-vol stations as shown in Table 4.  As shown in the table,
the ratio of suspended particulate concentrations calculated from the tailings
to actual measured total suspended particulate matter (Sm/Ss) ranged from
0.07 to 2.91, with an average ratio of 1.1.

At two stations, gravel pit operations add appreciably to the total
particulate loadings.  If these stations are not considered, the average
ratio is increased to 1.25.

Since the tailings hi-vol stations were all in close proximity to tailings
and, except where other known sources are also in proximity, most of the
particulate measured is from tailings.  However, there will in all cases be
some background contribution due to natural and man-made sources.  On the
assumption that this background would not be less than 10 yg/m3 the average
ratio  (Sm/Ss) is increased to 1.65.

The selection of the K value at 10~7 per metre appears to result in good
overall agreement between the model and the field results.  More detailed
calibration did not appear to be reasonable.

Annual contours of suspended particulate and dustfall were predicted by the
model to determine the extent of the effect of the emissions and to assess
the calibration of the model.  The model prediction of the present mining
and milling is presented in Figure 3.

A comparison of the suspended particulate model  to the air quality, Table  5,
results  indicates that  the model is reasonable.  The measured overall air
quality  at town monitoring stations was approximately  40 yg/m3  (arithmetic
average) while the tailings area contribution predicted by the  model  is  less,
ranging  from 8 to 17 yg/m3 at  locations in the general vicinity of  the

                                     -63-

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                                   TABLE 4
COMPARISON OF MODEL
MONITORING
SITE




STANROCK 1
2
3
NORDIC 1
LAB
SHERIFF LAKE
CROTCH LAKE 1
2
3
PANEL 1
2
QUIRKE 1
2
3
LONG LAKE 1
2
3
SURVEY

Number
of
Readings

31
30
29
73
66
51
38
35
9
5*
2*
48
28
8
13
13
15
WITH SUSPENDED PARTICUIATE
RESULTS

Arithmetic
Average
(Ss)
(vig/m3)
115.0
92.8
22.3
93.9
24.3
20.7
53.8
43.1
15.2
(10.4)
(43.5)
42.4
48.2
67.0
44.3
14.8
38.4
MODEL

FIELD STUDY


DISTA]
FROM j
Prediction Evaluation TAILI1
(Sm)
(yg/m3)

62
58
32
35
43
10
67
79
38
55
37
33
25
5
59
43
9
Sm/Ss


0.54
0.62
1.43
0.37
1.77
0.42
1.25
1.83
2.50


0.78
0.52
0.07 (1)
1.33
2.91
0.23 (1)
(m)


90
120
240
200
200
1000
20
20
50
20
20
120
30
1000
20
50
1000
AVERAGE OF ALL STATIONS







*Not enough readings for meaningful results




(1) Stations were ne*ar other known dust sources
1.1
                                     -64-

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                                            PRESENT  ANNUAL
                                       QUALITY  PREDICTIONS
                                                       -   FIG  3
-IlJ)> Boundary of exposed tailings
     Boundary of 2g/m2 + 30d dustfall
     and 20ug/m3 suspended
     particulate concentrations
O     Boundary of 4.6g/m2+30d dustfall
     and 30ug/m3 suspended
     particulate concentrations
      o
      L
              Kilometres
                                                                         -65-

-------
tailings and 4 yg/m3 in the more removed town of Elliot Lake.  Background
contributions include other fugitive sources such as gravel pits, unpaved
roads, and construction operation which also have variable emission
characteristics.  From the results of the particulate survey, these could
make up 20 +_ 10 Vg/m3 at any one location at any one time.

If the model predictions were increased by a factor of two, they would
approach the measured air quality and the amount left for other background
sources would be unreasonably low.

The same approach can be applied to the dustfall results. Table 6, and the
same conclusion reached.

As previously mentioned, the uranium mining industry on Elliot Lake is
undergoing an expension and the effect of the increase in tailings areas
is of concern.  The ultimate use of the model in using its ability to
predict trends and extent of the tailings dust on air quality was to deter-
mine the future air quality.  Overall air quality patterns only changed
slightly with the isopleths around the sources expanding, Figure 4.

Specific results at the critical areas of the townsites indicates that the
expansion of tailings will not have a significant effect on the existing
air quality,  Table 7.
                                   -66-

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TABLE 5
COMPARISON OF TAILINGS SUSPENDED PARTICULATE MODEL TO AIR QUALITY RESULTS

FIELD SURVEY RESULTS
Arithmetic
Number of Highest Lowest Geometric Average
MONITORING 24 h Reading Reading Mean (Xs)
STATION Measurements yg/m3 yg/m3 yg/m3 yg/m3
Elliot
Lake 55 136 5 35 42
Nordic
Townsite 29 121 6 30 39
Denison
Townsite 27 108 1 30 40
Quirke
Townsite 29 85 6 32 38
MODEL RESULTS
(TAILINGS ONLY)
Annual
Average
(Xm) Xm/Xs
yg/m3 x 100

3.5 10

17 45

13 35

8 20

-------
                                                      TABLE 6

                           COMPARISON OF TAILINGS DEPOSITION. MODELL TO AIR QUALITY RESULTS
                                                SURVEY RESULTS
                                                                                        MODEL RESULTS
                                                                                        (TAILINGS ONLY)
oo
      STATION
Hillside Drive
Kilborn Way
Roman Avenue
imber
of
;o d
•ements
11
10
8
Highest
Reading
g/m2
30 d
7.5
6.5
17.7
Lowest
Reading
g/m2
30 d
0.8
1.0
0.5
Arithmetic
Average
(Ds) g/m2
30 d
3.8
3.6
4.1
Monthly
Average (Dm)
g/m2
30 d

0.2

Dm/Ds
x 100

10%

      Denison Townsite
                               11
24.1
0.9
8.4
1.8
20%
      Quirke Townsite
                               11
 4.3
0.4
2.2
0.9
40%

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                                             FUTURE  ANNUAL
                                AIR  QUALITY  PREDICTIONS
                                             	         FIG  4
—
O
     Boundary of exposed tailings
     Boundary of 2g/m2 dustfall
     and 20ug/nri3 suspended
     particulate concentrations
     Boundary oh4.6g/m2-t-390d a dustfall
     and 30ug/rrt3 suspended
     particulate concentrations
              Kilometres
                                                                         -70-

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                                                     TABLE 7

                                COMPARISON OF EXPANSION CASE AIR QUALITY ESTIMATES

                                   IN RESIDENTIAL AREAS WITH PRESENT MEASUREMENTS
     Station
                                    SUSPENDED PARTICULATE
                               (pg/m  )  (geometric mean)


                             Existing
Expansion Case
Approximation
Existing
                                     DUSTFALL
                                    (g/m2. 30 d)
Expansion Case
Approximation
vo
i
ELLIOT LAKE

  Hillside Drive
  Kilborn Way
  Roman Avenue

DENISON TOWNSITE

QUIRKE TOWNSITE
                                      35



                                      30

                                      32
     37



     45

     44
  3.8
  3.6
  4.1

  8.4

  2.2
     3.9
     3.6
     4.2

     9.6

     3.7
      CRITERION
                                60
     60

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                                 BIBLIOGRAPHY
R. A. Bagnold, "The Physics of Blown Sand and Desert Dunes" Methuen and Co.
                    Ltd., 1959.

James F. MacLaren Limited, "Environmental Assessment of the Proposed Elliot
                    Lake Uranium Mines Expansion"
                    Volume 1   Background Information, March 1977
                    Volume 2   Background Information Update, February 1978
                    Volume 4   Environmental Assessment, April 1978
                    Addendum 1  September 1978

M. T. Mills, R. C. Dahlman, and J. S. Olsen, "Ground Level Air Concentrations
                    of Dust Particles Downwind from a Tailings Area During
                    a Typical Wind Storm", Oak Ridge National Laboratory, 1974.

F. Pasquill, "Atmospheric Diffusion" John Wiley and Sons Ltd., 1974.

G. A. Sehmel and M. M. Orgill, "Resuspension by Wind at Rocky Flats" Batelle
                    Northwest Laboratories, BNWL-1751, Pt. 1
                                       -71-

-------
IDENTIFYING SOURCES AND QUANTITIES
OF FUGITIVE EMISSIONS IN BALTIMORE
           Robert C. Koch
                 and
        John T. Schakenbach

        GEOMET, Incorporated
    Gaithersburg, Maryland  20760
                  and
         Kathryn G.  Severin

        IIT Research  Institute
      Chicago,  Illinois  60616
                -73-

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ABSTRACT

     Violations of Federal primary  standards  for  total  suspended particulate
(TSP) matter have been observed  in  the  Baltimore  area for the past several
years and, based on modeling results, are  expected  to continue to occur
through 1985.  A study was undertaken to estimate fugitive emissions  from
nonstandard sources and to analyze  hi-vol  samples to determine the types
of sources which are contributing to the concentrations  which are presently
exceeding standards.  The results of a  survey of  fugitive source character-
istics in the designated TSP nonattainment  area  in  the metropolitan Baltimore
area were used to estimate fugitive dust emissions.   Emissions from gravel
and dirt roads were found to account for 74 percent  of fugitive emissions.
Fugitive emissions in the nonattaintment area were  estimated  to be at  an
annual average rate of 10,000 Ib/hr.  A labortory analysis of 18 hi-vol
filters based on optical microscopy and a  battery of additional chemical
and physical tests were used to  characterize  the  filter  sample into six
source categories.  The analysis was made  on  half-filters and was repeated
for three samples.  The source type attributions  for sources  consisting
of over 15 percent of the sample were reproduced  within  12 percent of  the
original estimate.  The hi-vol filter analysis showed that 50 percent  of
the sample materials are.associated with fugitive sources.  Possible fugi-
tive emission control strategies were identified  based on these results
which will reduce fugitive emissions by 70  percent.   At  locations with the
highest measurements, the emissions controls  may  reduce  TSP concentrations
by 50 percent.  Future study of  the air quality impact of possible control
alternatives is recommended.
                                      -74-

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INTRODUCTION

     A study of suspended particulate matter in a selected portion of the
Metropolitan Baltimore area has characterized the types of particles which
contribute to exceedances of the National Ambient Air Quality Standards.
A survey of the nonattainment area was made to  identify fugitive sources
and estimate emissions.  Potential control techniques for reducing fugi-
tive emissions were identified.

     The total suspended particulate (TSP) air  quality problem  in the
Baltimore area is shown by the data in Tables 1 and 2.  Monitoring sta-
tions which exceeded Federal primary TSP standards  in 1975 or 1976 are
listed for annual geometric means in Table 1 and for second highest
24-hour concentrations in Table 2.  The  locations of these monitoring
sites are shown in Figure 1.
         Table 1.  Stations Exceeding Annual Primary TSP  Standard*
             in the Metropolitan Baltimore AQCR  in  1975  or 1976

Station
Fire Department HQ
Fire Department #10
Ft. McHenry
Fire Department #22
Patapsco STP
S.E. Police Station
AAI
Annual Geometric Mean
1975
86
128
86
86
150
78
(not operated)
( g/m3)
1976
74
164
105
82
144
77
90
  * Annual Standard =  75  g/m  geometric  mean.
                                      -75-

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      Table 2.  Stations  Exceeding 24-Hour Primary TSP  Standard*
           in the Metropolitan Baltimore AQCR in  1975  or 1976
Station
Riviera Beach
Fire Department #10
Patapsco STP
Lansdowne High School
Second Highest TSP Concentration (ug/m,)
0
1975
357
358
398
101
1976
174
559
509
271
* Primary  Standard = 250 vg/m  geometric mean.
                      Figure 1. Location of TSP monitoring stations

                       exceeding primary NAAQS in 1975 and 1976.
                                     -76-

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     A  nonattainment  area for TSP  was designated for Metropolitan Baltimore
as shown  in Figure  2.   This study  was conducted to determine the causes  of
the high  concentrations of TSP  in  this area  and to suggest  alternative
methods of controlling the contributions to  the high concentrations from
fugitive  emissions, which were  suspected to  be a major cause of the exceed-
ances.
                                                          -  City ttmiu
                                                        ___  County Umttf
                                                            Ncaattaiamaat ana
                     Figure 2.  Metropolitan Baltimore nonattayiment area for TSP,
                        including the three hi-vol stations used in the project.
                                         -77-

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     The Maryland  Bureau  of  Air Quality and Noise Control  (MBAQNC) collected
24-hour hi-vol  samples  at three sites  in the nonattainment area (see Figure 2)
during the  7-month period from June to December 1977.   Eighteen filters were
selected for physical and chemical  analysis to determine generic types of par-
ticKs collected.   The  particle types,  their relative  mass on each filter,
and their frequency of  occurrence  at each site and for different days helped
determine significant sources  or classes of sources.

     A ground-area, "windshield" survey was performed  by MBAQNC on the loca-
tion and characteristics  of  fugitive sources of TSP which  were not included
in the state emission inventory.   Types of surface material,  e.g., grass,
asphalt, dirt  and  gravel,  were identified along with quantitative factors
affecting emission rates,  including size, amount of vehicle activity, and
types of industrial activity.   The  survey results and  other data relating
to mobile sources  (i.e.,  cars,  trucks  and trains, etc.)  were  used to esti-
mate fugitive  emissions  in each square  mile of the city.   The estimates will
be used to  update  the state  emission inventory.

     A review  of control  strategies found in the literature was made to recom-
mend methods to  implement  for  each  of  six types  of fugitive particulate sources,
including paved  roads,  dirt  and gravel  roads,  construction and waste disposal
sites, wind erosion, railroads  and  storage piles.


FUGITIVE EMISSION  ESTIMATES

     The data  collected by MBAQNC  in its survey of fugitive emission sources
covered an  area  of 83 square miles  within the  City limits  of  Baltimore and
284 squares measuring 1,000  feet on a  side in  parts of the surrounding
Baltimore and  Anne Arundel Counties.   An inspector visited each area and
characterized  each open lot  or  other area by the type  of  surface,  its use
(e.g., parking,  recreation,  construction, unused, railroad, storage, etc.),
the type of terrain (e.g., open, enclosed,  steep slopes, etc.), the types
of emissions (e.g., vehicles,  stockpiles, material  handlers,  natural occur-
rences, etc.)  and  location identification data.   Special  characteristics,
reflecting mobile  activities were  also  noted,  including  the number of
various vehicles,  speed of vehicles, and frequency of  stockpile turnover.

     The Maryland  emission inventory was updated to include fugitive par-
ticulate emissions in two ways:  (1) by adding fugitive  emissions  from new
sources identified in the  survey, and  (2) by adding fugitive  emissions
from sources in  the present  inventory.   Both  the amount  of fugitive par-
ticulate emissions and  information  on particle sizes were  included in the
inventory data.  Fugitive  emission  factors  applicable  to each source were
developed from the available literature  and from data  obtained by  direct
contact with investigators whose work had not  been published.   The factors
were adapted to  the meteorological  conditions,  the materials  and the types
of activities  found in the Baltimore area.
                                      -78-

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Paved Roads

     The following emission factor for paved roads was derived from work
done primarily by Bonn  and Cowherd (1978):


            EF = 0.45 (s/10)(L/5000)(W/3)                              (1)


     where  EF = emission factor (Ib/vehicle mile traveled)

             s = silt content of road surface material (%)

             W = average vehicle weight  (tons)

             L = surface dust loading on traveled portion of  road  (Ib/mile).


There was not sufficient information available  to assign detailed  spatial
and temporal variations to the parameters  in this relationship.  Values
estimated to be representative for Baltimore were selected.   Street  runoff
measurements by Sartor and Boyd (1972) were used to  estimate  that  12 per-
cent  is a reasonable estimate of the silt  content.   The  average  weight of
vehicles was estimated to be  1.5 tons corresponding  primarily to light-duty
vehicles.  The dust loading of streets was assumed to be 17.7 Ib/mile based
on  informal discussions with  investigators in  EPA Region  III  and Midwest
Research Institute.  The resulting emission factor for Baltimore paved
roads  is 0.43 g(9.6 x  10   Ib) per vehicle mile traveled (VMT).


Unpaved Roads

      Emission factors  for unpaved roads,  including both  gravel and dirt
roads, were derived from the  EPA publication AP42  (1977).   The annual num-
ber of days per year with precipitation  greater than or  equal to 0.01 inches
was found to be  112 days for  Baltimore.   The  silt  content  of  gravel  roads
was estimated to  be  12 percent.   For  dirt  roads,  information  from local
sources was used  to estimate  the  silt  content.   The  following relation-
ship  was used to  determine emission factors:


            EF =  0.6(0.81)s(S/30)(l  -(P/365))                          (2)


      where  EF =  emission  factor  (Ib/VMT)

              s =  silt  content (%)

              S =  average vehicle  speed,  mph

              P =  days  per  year with 0.01  inch or more
                  precipitation or with reported snow cover.
                                      -79-

-------
 To apply equation (2) it  is necessary  to know  the  number  of  vehicle miles
 traveled, the average vehicle speed, and (for  dirt  roads)  the  silt content
 of the roadway.  If a better estimate  was  not  available,  vehicle  speeds
 were assumed to be 25 miles per hour.  When  applied to  parking lot traffic,
 vehicle speeds were assumed to be  10 miles per hour.  The  silt content of
 dirt roads was estimated for each  quadrant of  the  city  and found  to vary
 from 62 to 75 percent.

      In order to be compatible with other  emission  factors used in this
 study,  the EPA equation was multiplied by  0.6 to estimate  the  fraction
 of the  total particulate emissions with aerodynamic  diameters  less than
 30 urn.


 Construction Sites

      An emission factor for construction sites was developed from work by
 Cowherd and others (1974).  Emissions of 1.2 tons/acre/month (269 g/m /month)
 are representative of average construction activity and are assumed to repre-
 sent solid waste disposal sites which use similar types of operations.  Vari-
 ations  in activity levels may result in emissions varying  by a factor of two
 over a  period of a month.  Activity levels  are difficult to estimate without
 precise information on the nature and intensity of construction or disposal
 operations.   Since observations from the southwest United States were used
 to develop the emission  factor,  it may be high for east coast  areas.


 Wind Erosion

      For  fugitive  emissions due to wind erosion,  the following  emission
 factor  was used  based  on an analysis by Bonn  and  Cowherd (1978):


             EF = 381  (e/50) (s/15)  (f/25)  (PE/50)'2
                                      2
      where  EF = emission factor,  g/m /yr

              e = surface credibility,  ton/acre/yr

              s = silt  content of  surface material,  %

              f = frequency that wind exeeds 12  mph,  %

             PE = Thornthwaite's precipitation-evaporation  index.


For the Baltimore area,  the wind exceeds  12 miles per hour  21 percent  of  the
time  and the  Thornthwaite  precipitation-evaporation  index  is  108.   For sur-
faces common  in  the Baltimore area,  the surface credibility varies from 40  to
200 tons/acre/year.  For most clay  soils the  factor  is 85  tons/acre/year.   A
list of soil  credibility factors for various  soil textural  classes was com-
piled by Cowherd et al.  (1974).
                                     -80-

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Railroads

     An emission factor for railroad traffic was developed to treat the  large
amount of railroad volume much of which connects with the Baltimore Harbor.
Based on observations of rail traffic, conversations with railyard managers and
considerations of emission factors for other mobile sources, the emission
factor was set at 10 percent of the emission rate for unpaved roads.  The  silt
content of railroad loads was estimated at  10 percent and railroad car speeds
were estimated to be 15 miles per hour in the city limits and 40 miles per hour
outside the city limits.  Railroad data were used to estimate the railroad
car miles traveled in city and county areas.


Storage Piles

     An emission factor for aggregate storage piles developed from work  by
Cowherd et al. (1974) is as follows:
     where  EF = emission factor, g/kg  (placed  in  storage)

            PE = Thornthwaite's  precipitation-evaporation index.


To  apply this factor,  it  is  necessary to know the  amount of material moved
into the storage pile  over the course of a year.   This emission factor was
applied in the Baltimore  area to large  piles with  a material throughput on
the order of 100,000 tons per year  or more.


Summary of Fugitive Emissions

     There are many uncertainties associated with  the emission factors.
Based  on a review  of the  variability reflected in  the data used to develop
the factors, considering  the uncertainty of other  parameter estimates used
to  apply the factors,  and considering the uncertainty of the applicability
of  the factors to  the  Baltimore  area, it is estimated that over the course
of  the year  actual fugitive  emissions will be within a factor of 2 of the
calculated fugitive emissions.   On  any given day,  the emissions may be off
by  a greater  amount.   The validity  of the emission factors for determining
maximum 24-hour  concentrations  for  verifying compliance with National
Ambient Air  Quality Standards needs further study.  A summary of the emis-
sion factors  used  for  the Baltimore area is presented in Table 3.
                                       -81-

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  Table 3.   Summary of Fugitive Emission Factors and Required Source Data
  Type of Source
 Emission Factor
Required Source Characteristics
  Paved road


  Gravel road


  Dirt road
  Construction
    sites

  Wind erosion
  Railroads


  Storage piles
0.43 (g/VMI)
0.96 x 10" J (Ib/VMT)

61 S (g/VMT)
0.13 S (Ib/VMT)

5.1 sS (g/VMT)
0.0112 sS (Ib/VMT)
9.0 (g/rrT/day)
79 (lb/acre/day)

2.6 x 10"4 e s
  (g/mVday)

2.3 x 10"3 e s
  (Ib/acre/day)

6.1 S (g/VMT)
0.013 S (Ib/VMT)

0.14 (g/kg)
0.28 (Ib/ton)
 VMT (vehicle miles traveled)
 VMT
 S (vehicle speed, mph)

 VMT
 S
 s (silt content of road
   material, %)

 Site area
 Area
 s

 e (surface credibility,
      ton/acre/year)

  VMT
  S

  Quantity placed in storage
     When the emission factors and the-required source data are applied to the
designated nonattainment area of Metropolitan Baltimore, the fugitive emissions
presented in Table 4 are obtained for the portion within the city limits, the
portion outside the city limits and the total for the nonattainment area.  From
these results, it can be seen that, of the seven nontraditional sources, dirt
roads, gravel roads and construction operations contribute the greatest amount
of fugitive particulate emissions.  The emissions for unpaved roads (dirt and
gravel) amount to 74 percent of the total.  This only includes material kicked
up from the pavement and does not include tire wear or tailpipe emissions.
                                     -82-

-------
 Table 4.   Baltimore TSP Nonattainment Area Fugitive Participates (Tons/Day)
Type
Paved roads
Gravel roads
Dirt roads
Construction
Wind erosion
Railroads
Storage piles
Total
Within City
.
26
45
10
2
-
4
87
Outside City

12
5
9
4
_
2
32
Total
.
38
50
19
6
-
6
119
HI-VOL FILTER ANALYSIS

     The State of Maryland collected hi-vol filters at 3 sites  in the non-
attainment area where noncompliance with Federal standards had  been reported.
A total of 18 filters collected over a period of 7 months between June and
December 1977 were selected for microscopy and chemical analysis.  The location
of the sampling sites is shown in Figure 2.  The selected filters represent
different wind directions, wind speeds, and particulate loadings as shown  in
Table 5.  On 3 days filters were selected from all 3 sites; on  another 3 days
filters were obtained from 2 sites; and the remaining 3 filters were selected
on 3 separate days.  The wind speeds were slower than normal on the selected
days, varying from 2 to 6.5 as a daily average, comapred to the climatological
average for Baltimore of 10 miles per hour.

     Microscopy and chemical analysis were performed on the selected filters
by I IT Research Institute.  One-half of each selected filter was submitted for
analysis.  At the conclusion of the study, three additional halves, selected
at random from the original 18, were submittted for duplicate  analysis.

     The microscopy was performed by removing the  particles from a piece of
the filter half and viewing the particles optically under a high-powered
microscope which  is illuminated by polarized light.  The optical properties
observed to classify particles by different types  of sources  include trans-
parency, color, refractive  index, birefringence, reflectance,  pleochroism  and
fluorescence.  The physical properties observed  include size,  shape, surface
texture, magnetism, solubility, melting point and  density.  To identify par-
ticle types, the microscopist relies on reference  collections  of particle
data which  include atlases  of photomicrographs,  handbooks of  optical pro-
perties, the microscopist's previous experience  and actual  source  samples.
                                      -83-

-------
              Table 5.  Hi-Vol Filters Selected for Analysis


Date
6/9
6/21
7/15
8/2
9/19
9/25
10/25
11/24
12/12

Day
of
Week
Th
T
F
T
M
S
T
Th
M
f Sample no
Measured Concentrations (vg/m )
Fort
McHenry
59
136*
114*
154
69*
39
118
41
85
t analyzed
Fire
Dept.#10
63
145*
221
142*
165*
51
306
42
169
Fire
Dept.#22
—
60
149
93*
108
38
-
52
129
Rainfall (in)
Day of
Sample
1-36
0
0
0
0
T
0
0.01
T
Day
before
Sample
0
0.36
0
0.03
0
T
0
0.31
0

Wind
Speed
(mph)
6.2
6.3
2.0
2.8
3.5
6.5
3.2
4.3
4.6

Prevailing
Wind
Direction
S to SSW
WNW
ESE to SE
WNW
SW
ENE
E
W
S
•
     A simple particle counting and sizing procedure  is used to determine the
weight percentages of specific particle types present  in each hi-vol sample.
A mass per unit  area of the filter is determined for  each type of  identified
particle.  The sizing and counting procedure was used  to calculate mass  con-
centrations of silicate, calcite, hematite, rubber tire fragments, flyash, coal
and cornstarch.  Other types of particulates (e.g., ammonium sulfate, auto
exhaust, pollen  and magnetic fragments) were determined by nonmicroscopical
procedures, including low temperature plasma ashing,  plasma emission spectro-
scopy, scanning  electron microscopy and sulfate analysis.

     Low-temperature ashing determined the concentration of combustible  matter
such as starch,  pollens, and carbonaceous vehicle exhausts.  It generally
divided the samples between organic and inorganic materials.  A chemical anal-
ysis procedure was used to identify the sulfate concentration of the filter.
Lead and vanadium concentrations were analyzed by plasma emission  spectroscopy
to determine the concentrations of auto exhaust and oil soot particles  in the
sample.  The auto exhaust content is taken as 1.5 times the lead concentration,
and oil soot is  taken as 39 times the vanadium content.  The scanning electron
microscope was used to estimate the concentrations of  18 elements.  The  results
were helpful in  substantiating estimates obtained by  other methods.  Unfortu-
nately, the variation in elemental content of the filters themselves made
the estimates of doubtful value as an independent estimate.

     The analysis of hi-vol vilters revealed that six  types of particles
accounted for most of the material (from 70 to 96 percent) collected on
18 filters.  The percentages of each type, including  silicates, sulfates,
rubber, calcite, cornstarch and slag are shown in Table 6.  A summary of the
partciles classified by six types of sources using results from both micro-
scopy and other  analyses is presented in Table 7.  The mineral category
                                     -84-

-------
                                                             Table 6.  Predominant Materials Found on Hi-Vol Filters
 I
00
Ul

Station 6/9/77 6/21 7/1S 8/2 9/19 91
FD *10 Si 41* SI 40* Su
Su 21 Ca 30 SI
Ru 12 So 13 Ru
Ca 13 Ru 7 Ca
Total 87 Total 90 Total
Ft. McHemy SI 44* Co 41% Su
Su 3O. SI 23 SI
Co 11 Su IS Total
Total 85 Total 79

FO I2Z si 32* SI 54* SI 45* Su
Su 24 Su 16 Sn 22 Si
Ru 14 Ru 9 Ru 11 Ru
Total 90 Total 79 Total 78 Total

25 10/25
36% SI 31%
35 Ca 25
11 SI 17
10 Su 13
92 Total 96
SO* SI 44%
24 Su 18
74 Co 8
Total 70

40*
37
12
89

11/24
Su
Si
Ru
Total

Su
SI
Ru
Total

SI
Su
Ru
Total

35*
32
11
78

45*
32
14
91

35*
32
24
91

12
Ca
SI
Su
Ru
Total
SI
Su
Ru
Ca
Total
Si
Su
Ca
Ru
Total
/12
40*
30
13
8
91
33*
25
12
14
84
37*
17
14
10
78

                                 SI  =»illcate«
                                 Su = nlfatei
                                 Ru = rubber
                                 Ca = calcitc
                                 Co = conutarch
                                 SI  =flag
                                 Includes all material with * by weight MO only.

-------
                                  Table  7.   Summary  of  Particles Classified by Source Type
i
00
ON
Date
6/9/77

6/21/77
7/15/77

8/2/77
9/19/77
9/25/77


10/25/77

11/24/77


12/12/77


Site
FO 110
Ft. Me
FD 122
FO 110
FD 122
Ft. Me
-FD 122
FD 110
FD 122
Ft. Me
FD 110
Ft. Me
FD 110
FD 122
Ft. Me
FD 110
FD 122
Ft. Me
TSP
Concen-
tration
(ug/ra3)
63
59
60
221
149
154
108
51
38
39
306
118
42
52
41
169
129
85
Low
Tempera-
ture
Ashing
(% Removed)
41%
51%
44%
29%
40%
65%
42%
39%
50%
51%
23%
48%
45%
47%
60%
31%
40%
51%
Source Type
Minerals
%
57
49
54
71
58
30
56
46
39
29
44
50
40
40
35
70
56
48
Mobile
Emissions
%
13
3
15
8
10
5
12
12
13
7
4
8
13
26
16
9
11
13
Combus-
tion
Sources
%
3
4
3
4
7
2
6
5
5
10
4
9
8
3
4
2
4
7
Non-
specific
Combus-
tion %
23
31
24
16
20
16
24
36
40
50
16
23
37
33
47
19
22
28
Corn
Starch
5
2
12
1
1
4
43
3
<0.5
2
2
31
9
3
<0.5
1
1
3
5
Blolooicals
%
2
<0.5
4
1
1
1
1
<0.5
2
1
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5

-------
includes both soil and road surfaces.  Every sample contains  a high  percen-
tage of mineral content, but the percentage content is generally  highest
when the total particle loading (as  indicated by the TSP concentration)  is
highest.

     As a verification of the validity of the microscopy and  supporting  anal-
yses, 3 filter halves which were matches to the original 18 were  submitted
for analysis.  The comparative results are shown  in Table  8.  The mean dif-
ference between independent analyses of the same filter divided by the mean
of all measurements of a given particulate component  is shown in  the last
column.  This ratio varies from 0 to 0.85 for the  17 components listed with
an overall mean of 0.25.  These results are very encouraging  regarding the
reproducibility of the analysis.

     In summary, the results  in Tables 6 and 7  show that mineral  sources,
such as roadway kickup, constuction  operations  and wind erosion,  are the
major contributors to TSP loadings  in the Baltimore nonattainment area.
Another important source  is nonspecific combustion sources which  are pri-
marily evident by the presence of sulfates.  Particulates  from  mobile source
tailpipes are generally the third highest component of  particulate loadings.
A fourth type of particulate, which  is generally  small, but is  occasionally
the  largest  type, is cornstarch.


SUGGESTED CONTROL STRATEGIES

     Based on  the inventory of fugitive  sources of TSP  and the analysis of
hi-vol  filters,  it appears that dirt and  gravel roads  and  construction opera-
tions  are the major  local sources which  contribute to the  highest ambient
TSP  concentrations.  There  is also  a unique  and highly specific component of
TSP  due to cornstarch,  which  is  identified with a few very specific sources.
Controls for cornstarch  can  be  specific  to  these sources.   Alternative con-
trol strategies  for  dirt  and  gravel roads  and  an estimate of their effective-
ness in reducing  emissions were  developed  from various sources of emission
measurements.  The following  measures are  cited as effective, although their
costs  have not been  evaluated:

      1.  Paving  will  reduce  emissions by 99 percent.
      2.  Applying water  or  a chemical stabilizer will reduce emissions by
         50  percent.
      3.  Oiling  and  a double chip surface will reduce emissions by
         85  percent.
      4.  Reduce  vehicle speeds.
      5.  Decrease multiwheeled truck activity on  dirt and gravel  roads.

The  following suggested control  strategies for construction  sites  have  been
compiled,  but useful estimates of their effectiveness have not been  determined:

      1.   Regularly water exposed soil.
      2.  Keep handled materials at solid waste disposal sites wet.
      3.   Cover hauling operations.
      4.  Reduce  the free fall of materials handled.
      5.  Revegetate waste disposal  sites.


                                      -87-

-------
                     Table 8.  Results of Duplicate Microscopy Analysis
Component
Silicates
Calcite
Mica
Clays, humui
Hematite
Carbonaceous tailpipe
exhaust
Rubber tire fragment!
Classy ftyash
Coal fragment!
Oil soot
Fine carbonaceous
particles
Recrystallized sulfates
Const arch
Pollens, spores, conidia
Plant parts
Insect parts
Magnetic fragment*
Total
•« by Weight
Set 1
1st
23
5

-------
     About 70 percent of the fugitive emissions in the Baltimore area can be
eliminated by local area controls.  This would reduce overall TSP levels by
35 percent in areas where fugitive emissions constitute 50 percent of the
total TSP loading.  In areas with high TSP loadings, it is likely that fugi-
tive and other locally controllable emissions (e.g., corn starch and slag)
constitute over 70 percent of the TSP levels.  Therefore, the highest TSP
levels can be reduced by more than 50 percent.

     A relatively large degree of uncertainty exists concerning fugitive
emission factor estimates which are only weakly supported by measurements.
Questions concerning how representative the particulates caught on hi-vols
are of the particulates in the atmosphere necessarily raise some doubts
regarding how representative these samples are of what really makes up
ambient TSP matter.  The number of measurements used to derive emission
factors is small.  More data representing many variations  in roadway emis-
sions are needed to better estimate the impact of this  important source of
TSP  loading.


REFERENCES

Bonn, R.C.T., Jr. and C. Cowherd, Jr.   1978.  "Fugitive Emissions from
      Integrated  Iron and Steel Plants."  MRI, Kansas City, Missouri.

Cowherd, C., Jr., K. Axetell, Jr., C.M. Guenther, and G.A. Jutze.   1974.
      "Development of Emission Factors for Fugitive  Dust Sources," MRI,
      Kansas City, Missouri.

Sartor, J.D., and G.B. Boyd.   1972.   "Water  Pollution Aspects  of Street
      Surface Contaminants."  Publication  No.  EPA-R2-72-081.   Environ-
      mental Protection Agency.

U.S.  Environmental Protection Agency.   1977.   "Compilation of  Air  Pollutant
      Emission Factors"  (Including Supplements  1  through  7).   Third  Edition.
      Research Triangle Park, North Carolina.
                                       -89-

-------
   FUGITIVE EMISSIONS FROM THE BY-PRODUCT COKE OVEN PUSHING OPERATION
                            Robert B. Jacko
                           Purdue University
                        West Lafayette, Indiana
                                ABSTRACT


     An intensive sampling program at the by-product coking facility of a
major midwestern steel company has quantified the release of trace metals
and other participate to the atmosphere resulting from the "pushing" operation,
Emission factors and emission rates were obtained from "clean" (completely
coked) and "green" (incompletely coked) pushes.  A number of coke oven push
plumes were sampled isokinetically at a rate of approximately 30 SCFM.  The
sampling head with associated temperature and velocity sensors was suspended
over the quench car by means of a tower/boom arrangement mounted on a mobile
laboratory.  The cross sectional area of the plume in the horizontal plane
of the sampling was determined by measurements on motion picture films
taken from two vantage points.  The mass emission rate of total particulate
was calculated from the particulate concentration, plume velocity and cross
sectional area.  Trace metal emissions were quantified by atomic absorption
analysis of all particulate samples for Cd, Pb, Zn, and Cu.
                                   -91-

-------
                                 INTRODUCTION

    A  total of 66 coke oven  pushing  plumes have been sampled using a specially
designed mobile laboratory  for characterizing the plume parameters of tem-
perature, velocity,  shape,  and particulate emission.  An earlier publication
by  this authorl reported on the  first 15 samples while this work concentrates
on  the complete sample set  of 66.   This paper will be helpful to those invol-
ved in the quantification and control of coke oven pushing emissions and the
design of fugitive emission sampling techniques.

                          MEASUREMENT METHODOLOGY

    The pushing emission can be classified as a "fugitive emission" of sorts
in  that it does not  emanate from a  confined conduit or stack.  As such,
quantification of the particulate emissions has a "high degree of difficulty"
and requires a special experimental design.  The basic approach in this study
was to place sampling nozzles and sensors for temperature and velocity in a
stationary plane in  the plume over  the duration of the push.  Meandering of
the plume around the sampling nozzle caused by atmospheric motion reduced the
biasing effect of large variations  in plume parameters.  Figure 1 contains a
cross-section view of the sampling  apparatus aligned adjacent to the coke
oven.  Note the mobility of the apparatus and freedom of any supports from
the coke oven structure itself.  This provided for unrestricted movement
of  the sampling laboratory and no interference with the coke oven production
schedule.  The sampling nozzle and  instrumentation were at the elevation of
the top of the coke  guide and positioned approximately over the center of the
quench car.

    Temperatures were measured with two iron/constant and thermocouples at
the end of the boom.  A cup anemometer provided plume velocities and parti-
culate samples were  taken at a rate of approximately 43 scfm through 8 x 10
inch  glass fiber filters.

    Cross-sectional plume shape was determined by taking 16 mm black and
white motion pictures in two planes over the duration of each push.  Subse-
quent stop-action projector analysis yielded plume cross-sectional  dimensions.
The camera set-up is shown in Figure 2.   Since the motion picture camera
frame rate was calibrated, plume velocities could be checked by use of a
stop watch.  In addition, the gas sample volume was easily corrected for
those instances where the sampling nozzle was not in the plume by examina-
tion of the film.

    The particulate concentration was determined by drawing a gas sample at
an  approximate rate  of 43 scfm through an 8 x 10 inch glass fiber filter.
The gas sample volume was determined with an orifice plate and the sampling
rate was controlled  from within the vehicle to achieve an isokinetic rate
as a function of the anemometer readout.   The reader is referred to the pri-
mary author for specific hardware details.   Knowing the weight of coal
charged to each furnace, an emission factor was subsequently computed for
each push.
                                    -92-

-------
                           RESULTS  AND DISCUSSION

Plume Temperature

   Fifteen of the 66 pushes sampled were taken  in  December  and  the  remaining
in April.  Since the steel  mill  was located in  Northwest Indiana, ambient
temperatures were significantly different in each  of these  seasons.   The
December ambient temperatures were  close to 0°F and the April temperatures
were close to 40°F.   This difference in temperature is partially reflected
in average plume temperatures seen  in Table 1.

                                  TABLE 1
                    Coke Oven Push  Plume Temperatures °F

                    No. of        Average       Range       One Standard
                    Samples                                 Deviation

          DECEMBER
            Green      7            157         81-309         77
            Clean      8             89         77-108         11
            Overall    15            121         77-309         62

          APRIL
            Green     33            232        109-534        101
            Clean     18            117         71-167         25
            Overall    51            191         71-534         99

Note  from Table  1 that the green push  plume temperatures are about twice
that  of  the clean pushes regardless of the  season.   This is a result of the
incomplete combustion of the remaining  volatiles  in  the green push coke and
the  attendant  flames.  Also, the range of  plume temperatures is quite wide
from  71  F to 534 F  as  is probably  expected  but  it is interesting to note that
the  clean pushes have a  significantly lower standard deviation value as com-
pared to green pushes.   The  December  and April  standard deviations were 11
and  25 F for the clean pushes respectively and  77 and 101  for the  green
pushes.  Apparently, the clean  push  plume  temperature is more closely re-
lated to the coke temperature which  is relatively constant from push to
push  as  compared to a  green  push whose temperature is probably more closely
related  to  the amount  of flame  in  the plume which can vary greatly from one
green push  to  another.

    The temperature-time  history characteristic  curve would be  of interest to
those designing capture  hoods  or other control  devices.   Figure 3  contains
a plot of  the  three temperatures recorded  over  the 66 pushes sampled.  Note
that the maximum temperature was 534 F and corresponds to  a green  push.  The
average rate of increase in  temperature for the three temperature  curves
 in Figure  3 was 4°F/sec  with the maximum occurring about  40* of the  total
time into  the  push.

 Plume Velocity

    The buoyancy of  the push plumes result in a vertical  velocity which was
measured with a cup anemometer whose cups were located in a vertical  plane.
 Table 2 contains the average statistics.


                                       -93-

-------
                                  TABLE 2
                        Push Plume Velocity, ft/sec

                 No. of         Plume      Velocity     One Standard
                 Samples        Average    Range        Deviation

       Green       40            15.7     6.8-21.3          3.9
       Clean       26            14.1     6.2-20.9          3.3
       Overall     66            15.0     6.2-21.3          3,7

From Table 2 it is seen that the average and range of plume velocities
are not greatly different for the clean or green pushes.  Note also that one
standard deviation about the average value is not exceptionally large and
reflects the relatively consistent plume velocity from push to push.  The
overall range, however, is quite wide from 6.2 to 21.3 ft/sec; a 3.5 to 1
change.

   Figure 4 shows a typical green push velocity-time history plot.  Note
the erratic nature of the trace reflecting the billowing nature of the
plume.  Also, the peak velocities occur about 15 seconds in the push, are
sustained for 15 seconds and decay in about one-half the time it took to
reach peak velocity.

Plume Cross-Sectional Shape

   Analysis of the two motion picture film records which were shot at approx-
imately 90° to one another (Refer once again to Figure 2) allowed the plume
cross-sectional shape to be defined.  The procedure involved the use of a
stop action projector and measuring the plume width frame-by-frame for each
90° view.  Table 3 shows the resulting plume dimensions.

                                  TABLE 3
                        Plume Cross-Sectional Shape

                            Plume Shape, ft.     Range       One Standard
                                Average                        Deviation

         Length "A"              18.2            10-29           3.8
         Length "B"              17.8            10-31           5.6
         Overall                 13.0            10-31           4.7
         Ratio of "A"/"B"          1.02           1.0-0.94        0.3

Note that the two diameters are very nearly equal  with a ratio of 1.02.   This
Indicates that a circular  plume cross-sectional  area is a reasonable model
to use for estimation of the emission parameters.

   From Tables 2 and 3 the plume volumetric flow rate can be estimated on an
average basis.  Table 4 shows the plume actual  volumetric flow rate as cal-
culated from the statistics in Tables 2 and 3.
                                     -94-

-------
                                  TABLE 4
                     Plume  Actual  Volumetric  Flow  Rate
                     Average
                     One Standard Deviation
                       about the average
                     Observed overall  range
                        ft3/m1n

                        229,000
                         94,000-454i000

                         61,000-920,000
Table 4 Indicates the average volumetric flow rate to be 229,000  actual
ft3/m1n.  Using one standard deviation value to both reduce  and increase  the
plume diameter and velocity a one standard deviation range on  volumetric
flow rate was calculated.  This range as seen 1n Table 4 1s  94,000 to
454,000 actual ft3/m1n.  The observed minimum and maximum values  are also
shown in Table 4.

   These volumetric flow rates are of interest to those Involved  1n the
design of control hardware and yield an estimate of gas flow rate that must
be handled.  However, keep in mind that these measurements were made 1n the
open atmosphere where gaseous and particulate diffusion 1s relatively  un-
limited.  If the control hardware confines the push plume, significantly
lower plume volumes will probably result.  One reason for this 1s the  re-
striction on plume diffusion and dilution.  For green pushes,  a  confined
duct limits the amount of oxygen available to the remaining  coal  volatiles
thus Inhibiting combustion and therefore temperatures which  results in
lower volumetric flow rates.

Particulate Emissions

   The  concentration of  partlculates measured in the push plume is seen
1n Table 5.

                                  TABLE 5
                 Push Plume Total Particulate Concentration*
                                                          One Standard
                   No. of      Range  3       Average-     Deviation.
                   Samples      grams/m        grams/m        grams/m
         Green
         Clean
         Overall
39
25
64
0.22-16.0
0.07-5.0
0.07-16.0
3.3
1.8
2.7
2.9
1.2
2.5
         *per  standard conditions of 70  F, 1 atm
    As  expected,  the  green  pushes  have  a  significantly  higher  particulate  3
 concentration  relative  to  a clean push.   The  green  pushes were  3.3  grams/m
 as  compared  to 1.8  for  clean.   Note  the  large standard deviation  for  both
 the green and  clean  pushes.  The  coefficient  of variation  (average  •»  std.
 dev.  x 100)  for green and  clean pushes 1s 88% and 67%  respectively.

    Emission  rates and factors  of  total  partlculates are shown in  Table 6.
 The emission factors are  based on steel  mill  records of coal  charged  for
 each push sampled and Indicated an average oven charge of  30,000  Ib-coal.
                                     -95-

-------
                                   TABLE  6
                      Summary of  Mass  Emission Rates and
                   Emission  Factors for Total Participates

                          No.  of        Range       Average     One Standard
                          Samples                               Deviation

      Mass  Emission
      Rate  (grams/sec)
              Green          39        21-1495        382          335
              Clean          25        11-377         138           79
              Overall        64        11-1495        287          291

      Emission Factor
      (Ib/ton-coal)
              Green          39      0.09-9.0         2.0          19
              Clean          25      0.05-2.0         0.7          0*4
              Overall        64      0.05-9.0         1.5          l.*6

    In  an earlier  paper  ,  the  average mass emission rate of the first 15
 December samples  was reported.  The values were 407 grams/sec for green
 pushes and  147 grams/sec  for  clean pushes.  It is interesting to note that
 these  values  compare favorably with those reported for the total  sample
 set of 64.  In other words, the initial  15 samples when reported were
 reasonably  representative of  the larger sample mean composed of many more
 samples.

   The emission factors expressed as Ib-part./ton-coal  charged range from
 0.05 to 9.0,  a change of  180  to 1.  This  is a  relatively wide variation and
 is reflected  in the large standard deviation values.   The resulting "coeffl
 cient  of variation" for green and clean pushes is 95% and 57% respectively
 This indicates the clean  push emission factors are not  quite as variable
 as the green  pushes and reflects the degree of flame  and remaining volatile
 in green push.                                                           Ies

   The average emission factors are of interest  and were 0.7 Ib/ton for the
 clean  pushes  and  2.0 Ib/ton for the green pushes.  The  overall  value was
 1.5 Ib/ton.   The  emission factor reported in "AP-42"  for total  participates2
 for coke "discharging" is 0.6 Ib-part./ton-coal  charged.

   The distinguishing feature of the emission  factors  is the wide  variability
 However, whether or not one will  experience a  green or  clean push  appears  to
 be directly related to the individual  coke oven.   In  this sampling program
 the same ovens were repeatedly sampled.   Upon  analysis  of the data it
 appeared that a specific oven would either yield  a clean push or a green
 push.   Table 7 contains a listing of the  ovens that were sampled three  or
more times and how many of the samples were classified  clean or green.
                                    -96-

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                                 TABLE 7
          Characterization of  Coke  Push Plumes by  Individual Ovens

          Oven        No.  of  Times      No. of Green     No. of Clean
          Number        Sampled            Plumes            Plumes

            49             5                05
            52             3                03
            54             4                13
            57             5                41
            59             5                50
            52             4                40
            64             4                04
            67             3                30
            69             5                50
            72             4                40

It is interesting to note that ovens #49,  52,  54  and 64 were  sampled  16
times and all  were clean  pushes except one.  This  contrasts to the record
of ovens #57,  59, 62, 67, 69 and 72 which  were  sampled a  total of 26  times.
Of these, all  were green  pushes except one.  These results suggest that  a
clean or green  push is a  function of the oven  from which  it came.  It may
be related to  the condition  of the internal  heat  transfer surfaces and to
the time between rebuilds.  It should be  stated that no correlation whatso-
ever was found  between the coking times  and  the particulate emission  factors.

                          SUMMARY AND CONCLUSIONS

   For the 66 coke pushing plumes sampled  the  overall average parameters
observed were:

             1)  temperature                   176 F
             2)  velocity                       15 ft/sec
             3)  shape                         circular w/ratio front
                                                 to side - 1.02
             4)  volumetric flow rate          229,000 ACFM
             5)  particulate concentration     2.7 grams/m3
             6)  particulate emission rate     287 grams/sec
             7)  particulate emission factor   1.5 Ib/ton coal  charged

   Specific significant  differences were measured for  green and  clean pushes.
Generally,  green  pushes  were  greater  in all of the  above  parameters  by  at
least  2  to  1 except  the  velocity which was approximately  the same.   The one
dominant facit regarding all  of the pushes sampled  was the wide  variability
1n plume parameters  not  only  between  green and clean  but  within  each of these
categories.  One  standard deviation values expressed  as  a  percentage of the
mean value  approached  100%  in some cases.

   The data suggested  that  a  green or clean push  is a  strong function of  the
oven from which  it came. Repeated sampling of the  same  ovens showed a  trend
that some ovens  produce  consistently  clean pushes while  others yield green
pushes.   Oven  maintenance and condition may be the  important factor  here.
                                     -97-

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                                 REFERENCES

1. R.B. Jacko, D.W. Neuendorf and J.R. Blandford, "The By-Product Coke Oven
   Pushing Operation:  Total and Trace Metal Participate Emissions", APCA
   paper no. 76-12-2 Portland, Oregon, 1976.

2. "Compilation of Air Pollutant Emission Factors", U.S. EPA, 2nd edition
   1973.                                                                 '

                              ACKNOWLEDGMENTS

   The research described in this paper was supported by the National  Science
Foundation Research Applied to National Needs (RANN) under Grant  No. GI-
35106 and the Environmental  Protection Agency under Grant No. T900196.
                                    -98-

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                        CHARGING
             BY-PRODUCT CAR
             COLLECTION
             MAINS
DOOR
MACHINE
    PUSHER
    CONTROI
    CAB
RAM
     PUSHING
     MACHINE
     COKE
     6UIDE SAMPLING
          HEADS
               BOOM  BLOWERS
                              COKE  OVEN
                              •••••••
                             RECUPERATOR
            QUENCH
            CAR

        WASTE
        HEAT FLUE
           Figure 1 VIEW OF COKE OVEN AND SAMPLING VEHICLE PLACEMENT
                                 -99-

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                               Coke Oven
                               Push Plume
   o-'
Camera
   B
                                              Quench Car
                                 6
                              Camera

                                 A

           Figure 2 TOP VIEW OF PUSH PLUME MOTION PICTURE CAMERA SETUP
                          -100-

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   600
   500
  400 —
I
   300
   2OO
   100
                        10
15      20       25

TIME INTO PUSH SECONDS
30       35
40
       Figure 3 COKE OVEN PUSH PLUME TEMPERATURE -
               TIME HISTORIES FOR THE 3 HIGHEST TEMPERATURES MEASURED
                                     -101-

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10
                    10
15        20      25
TIME INTO PUSH SECONDS
30
35
   Figure 4 COKE OVEN PUSH PLUME VELOCITY-
           TIME HISTORY FOR A TYPICAL GREEN PUSH
                                 -102-

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               ESTIMATING  DUST  PRODUCTION  FROM  SURFACE MINING
                                      by

           Karl  F.  Zeller,  Douglas  G.  Fox,  and  William E.  Marlatt-
—  Bureau of Land Management, Denver, Colo.; USDA Forest Service, Rocky
Mountain Forest and Range Experiment Station, Fort Collins, Colo.; and
Department of Earth Resources, Colorado State University, Fort Collins,
Colo., respectively.
                                     -103-

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                                   ABSTRACT

     The Federal Land Manager has a responsibility to evaluate the effects of
activities he conducts, or permits to be conducted under his administrative
jurisdiction, on the air resources of the United States.  The operation of
surface mining  is among these activities.  Regulatory classification of surface
mines suggests the need for studies of the emission of particulates from them.
In particular, two aspects of the emission must receive attention; namely,
the chemical/physical characteristics of the particulates, in order to deter-
mine what portion of the total particulate burden is "fugitive dust" and what
portion is industrial pollution, and secondly, the emissions resulting from
specific mining activities such as crushing, screening, dragline overburden
removal, stockpiles, etc., must be determined.

     This paper describes a preliminary study designed to characterize these
emission factors for surface coal mines in and around Craig, Colorado.  The
study includes consideration of such off-site impacts as deposition downwind
of the site, and effects on visibility.   The approach includes a general
characterization of source configuration and the dispersion pattern, which
should lead to an improvement in dispersion modeling for surface mining.
Modeling approaches used to calculate downwind concentrations and surface
deposition will be reviewed, leading to suggestion of a preferred model.
Finally, the main data collection phase of this study will be described.
The result will be an improved set of emission factors for surface mining.
Future plans to investigate the effects of BACT will  also be described.
                                     -104-

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                 ESTIMATING DUST PRODUCTION FROM SURFACE MINING

                              I.  INTRODUCTION

     Wind blowing over the surface of the earth often generates enough shear
stress to mobilize particles in the first few centimeters of the soil.
Especially during drought, the amount of material introduced into the atmos-
phere by wind can be extremely large.  The magnitude of the effect depends
strongly upon soil type, vegetative cover, and soil  moisture content.  Natural
surfaces, particularly in arid and semiarid regions, develop a "shear-proof"
layer that resists wind erosion.  Any activity that  disturbs the "shear-proof"
layer will then cause an  increase in blowing dust.

     Besides surface mining itself, construction and use of roads, blasting,
and overburden removal all increase dust emissions from the surface.  How
increased mining in the semiarid regions of the Western United States can be
conducted with minimal effect on the atmospheric environment is particularly
important now that the Clean Air Act Amendments of 1977 require that certain
federal lands in the Western United States be managed so that virtually no
air quality degradation occurs there.

     Recent regulatory proposals from the Environmental Protection Agency
(Fed. Reg. ^3., 118, 19 June 1978, p. 20395) clarify the application of the
concept of PSD (prevention of significant deterioration) to surface mining and
discuss the question of fugitive dust.  These regulations affirm  that surface
mining  is a stationary source subject to PSD  review, but that fugitive dust
(defined as particles of  native soil uncontaminated by pollutants from
industrial activity) will be excluded from such  consideration.  This exclusion
will be  reviewed periodically by EPA pending more information, and when new
sources are planned, "...the burden of  showing  to what extent emissions from
the proposed source or modification would be made up of fugitive  dust rests
with the applicant".  Fugitive dust  is  not excluded from estimates of poten-
tial emissions (a test to determine  if  PSD review is needed).  Any mine that
emits more than 250 tons  of particulates per  year,  including fugitive dust,
must apply BACT  (Best Available Control Technology).

     This regulatory classification  underlines  the  need for studies  of
particulate emission from surface mines.  Two aspects of the emission must
receive  particular attention,  the chemical/physical characteristics  of the
particulates  (to determine what portion of the  total particulate  burden  is
"fugitive dust" and what  portion  is  industrial  pollution)  and  emissions
resulting from specific mining  activities  (such as  crushing,  screening,
dragline overburden removal, and stockpiles).   The  effectiveness  of  BACT
must also be evaluated.

     The  Bureau of  Land Management  (BLM)  is  responsible  for evaluating the
impact  of mining  its  leased minerals.   To  evaluate  air  pollution  from surface
coal mining  in the  area around  Craig,  Colo.,  the BLM  is  supporting  a coopera-
tive  research effort  between  the  Rocky  Mountain Forest  and Range  Experiment
Station and  Colorado  State  University.
                                     -105-

-------
      The major  activity  in  the  study will  be  field measurement  to determine
 type,  size,  and chemical  separation of  particulates  at  various  locations
 downwind from the mine source.  Meteorological  conditions will  also  be
 measured so  that modeling can be  used to  relate the  particulate measurements
 back  to emissions and the amount  of activity.   The objective will be to
 determine emission  factors  (i.e.  emissions as a function of  incremental
 activities)  for surface mining.

      To characterize the  impact of surface mining on  the environment, we will
 conduct two  additional activities.  One will  establish  a deposition  monitoring
 site  near Craig to  provide  information  about wet and  dry removal of  pollutants
 from  the atmosphere.  This  site will be a component of  NC-141,  USDA  Regional
 Atmospheric  Deposition Project, which will be collecting similar data
 throughout the  United States.   Data collected at Craig  can be evaluated
 relative to  the entire country.

      The second, somewhat speculative activity  is related to visibility.
 Visibility has  been a major  issue in public concern about air quality for many
 years.  The  impact  of surface mining on visibility is largely unknown.  The
 assumption that most of the  particulates generated from mining  are large
 enough to cause scattering of visible radiation will  be tested  in a  study of
 background visibility in  Northwestern Colorado.


                       I I.   CURRENT STATE OF  KNOWLEDGE

      The latest numbers for  emission factors from surface mining, taken from
 a  recent EPA study  (EPA-908/1-78-003, Survey of Fugitive Dust From Coal Mines,
 by PEDCo Environmental,  Inc.) are shown in Table 1.  While these numbers give
 some  indication of  the particulate loading from mining  activities, they do
 not segregate soil  from coal particulates, nor  are the  data sufficient to
 determine site-specific emissions numbers accurately.   Some shortcomings of
 the numbers  in  Table 1 are that there is no consideration of such factors as
 soil  surface conditions,  or moisture content, and that  the numbers are based
 upon application of a Gaussian model to the entire source area.

      Recent work has characterized the  background dust  from the semiarid
 Southwestern United States  (Gillette et al. 1978).  Although the soils are
 somewhat different, climate conditions  in the Craig vicinity are similar, and
 one would expect roughly  similar atmospheric  loading.

     The results of this work that are most applicable  to our study concern
 particle size distributions.  Only small particles (less than 10 \im)  are
 found at altitudes above  1 km, and they are associated with major dust storms.
Sampling at ground  level   (1  m) showed a dust size distribution similar to the
aloft aerosol along with a large concentration  of particles in the ^0-80 ym
diameter range.   Clearly, the fine aerosols are well-mixed through the lower
 troposphere,  while  the large particles  remain near the  surface.  For this
 reason, the major long range impact of surface  mines  is the aerosol  produced
 in the size range below 20 vim. This research also suggests that accurate
measurement of dust size  distribution at one location above the surface may
suffice to characterize the total  dust produced by the mining activity.
                                     -106-

-------
     However, the PEDCo report determined particulate loading by measuring
concentrations with high volume samplers on or near (1-3 m above)  the  ground.
Such sampling might overestimate the amount of dust exported from the  site,
unless a method of simulating the dispersion and deposition were incorporated
into the analysis.

     Modeling was done in the PEDCo study to relate measured concentrations
back to emissions from the source.  The model used is the standard Gaussian
distribution,
                                y z

where  x  =  concentration, g/m

      a   «  vertical standard deviation of plume concentration distribution,
             m

      a   =  horizontal (perpendicular to plume) standard deviation, m

       u  =  mean wind speed, m/sec

       a  and a  are determined from the equations


                               ay  =  c(x + XQ)                           (la)
                               az  =  a(x = x0)b


where a, b, and c are given in Table 2 for different stabilities, and XQ is
determined by observation of the initial distribution of pollutant mass.

     Since it is not appropriate to model dust concentrations without simula-
ting deposition, the PEDCo study used a simplified version of the source
depletion method originally developed by Van der Hoven  (1968).  The source
depletion model deals with deposition by reducing the effective source
strength.  Two other modeling approaches, the tilted plume and a surface
depletion model, are available.


Tilted Plume

     The tilted plume model is a straightforward combination of the Gaussian
diffusion formula with a steady particle mass fall velocity.  Assuming  that
the particles in suspension can be described by a discrete size distribution,
the fall velocity for particles in the j compartment  is

                         X  =  ZXj  and  Vd  -  ZVdj


                                     -107-

-------
 (given for a limited set of Reynolds numbers, gdj2/l8v).  The trajectory of
 the particles is tilted at an angle, a, given by
                            —  i.e.  a.  -  ,a,.
                             u         j            u
 In order to simulate removal from a plume assumed to be released (or have a
maximum plume rise) at height h, then simply replacing z by
                                                Vdi
                          h - x Sin a. «  h - x

so the area source expression becomes


              *  =  ash-  exp [-J(a-)2  -  * 1-^)1             (2)
                       y z      L       y

The deposition flux is given by

                                Wj   =  VdjX                             (3)

This model assumes a completely absorbtive surface with no provisions for
particle "bounce" or resuspension.


Source Depletion

     The source depletion model simply accounts for a removal  by replacing
the emission by an effective emission, Q*, where

                                 Q*  =   £ Q*


in equation (1).  Then employing conservation of mass, one can relate the
change in effective emissions to the deposition flux

                 dQ*      /•            /•
                 -di  =  / Wjdy  =   -  / Vdj X (x,y,o) dy                (k)
Since this integral has been evaluated for a number of cases,  the depletion
factor Q* can be calculated by ratio.


Surface Depletion

     A more sophisticated and physically realistic model  allows  the  removal
of material directly at the encountering surface.   Within the  Gaussian
approximation, this is accomplished by including negative source distributions
along with the positive source.   Horst (1977)  has  developed  this model  by
assuming, for the case of an area source, that deposition will occur at a
point (^.m.zj) which causes a reduction In concentration  at  (x,y,z)  downwind,
equal to       r                      ,    '
                  j X U,m,zd) d £ dm) J  (x - i,y - m,z)                 (5)


                                    -108-

-------
In order to calculate concentration, one sums the source contribution and the
total deposition (integration of equation (5) over the total  domain of deposi-
tion), i.e.
                                 00   V
                  n              f  C   V
     X(x,y,z)   =  S  G(x,y,h) -  /   /   -Hi x(£,«.zd) G(x-£,y-m,z) d I dm (6)
                                -00   0

This has the advantage of allowing specification of the deposition domain, of
differential deposition rates, and similarly, of a resuspension coefficient
should such a  mechanism be needed.

     Cole and  McVehil (1977) applied these three models to a surface mine for
estimating dustfall rates and particulate concentrations.  For the material
they were concerned about they estimated that the dj  (distribution of particle
diameters) was approximately kO% with d > 44 ym, and 20% with d < 20 ym.  After
comparison with experimental results, the most successful model they employed
proved to be an integrated version of equation (6).  Their results further
indicated that some re-entrainment of already deposited dust was necessary to
properly predict dustfall rates.   In view of this result, our major effort
will be oriented toward properly defining the parameters for equation (6),
which will provide the most accurate simulation of reality.
                             Ml.  FIELD PROGRAM

     In order to assess the impact of surface mining on the atmospheric
environment, we are planning a field exercise at a surface mine in the vicinity
of Craig, Colorado (fig. 1).  We plan to initiate both short-term and long-term
studies.  The short-term studies will include meteorological characterizations
of the  immediate source area and detailed measurements of the mass of particu-
lates suspended in the atmosphere and deposited on the ground surface.  Data
will also be collected to determine specific mining activities and amounts of
material processed per unit time.  Meteorological data will be collected on
site, using a tethered balloon system and an array of surface stations.
Hopefully the study site will be located near a meteorological data tower
that has long-term data that will help in planning the timing of our  intensive
data collection periods, as well as assessing the general applicability of our
results.

     Short-term studies will also include a particulate emission study at the
Craig,  Colorado Utah  International Coal Mine.  A brief description of the field
research plan for this study follows.

     Delay  in starting operation of the Colorado Ute Yampa power plant has
resulted in a large stockpile of coal in open fields south of Craig,  Colo.
Currently,  some of this stockpiled coal is being crushed and sold by  Colorado
Ute.  A study of this stockpile area is proposed.  Downwind distribution of
fugitive dust around  the area will be investigated as a function of wind,
atmospheric stability, particle size, material composition, and coal  handling.
The objective is to determine how far downwind significant amounts of coal and
overburden  remain airborne  under different wind and stability conditions.
                                     -109-

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Meteorological Measurements

     Wind and air temperature measurements aloft are available from a tower
near  he study site operated by Sterns-Rodgers under contract to Colorado Ute.
Three-dimensional wind and turbulence data will be taken using Gill u,v,w
anemometers mounted on towers at 200 and 600 m downwind from the aforementioned
coal stockpile.  Also, a tethered balloon sounding system will be available
to provide additional information (wind speed and direction, temperature and
humidity) at any elevation up to 600 m above the surface.  As timing and
logistics permit, a monostatic acoustic sounder will be deployed to measure
inversion depth  in the area.

Particulate Measurements

     Dustfall measurements will be taken, using Petri dish collectors spaced
in the grid pattern illustrated in figure 2, at intervals no larger than 320
m.  Close to emission sources, collectors will be located at 160 m intervals.
Petri dishes will be placed at approximately the canopy foliage maximum
elevation (15 cm).  They will be exposed long enough to allow collection of
an analyzable sample, but hopefully for a short enough period that stockpile
activity (crushing, etc.) remains constant.  The Petri dishes will be fitted
with an artificial turf material to improve their collection efficiency and
reduce loss from particle bounce.  In order to provide a cross reference,
selected vegetation samples will be taken to help establish the validity of
the Petri dish collectors.  Total mass, size distributions, and, via micro-
scopic observation, percentage of coal/surface soil, will be determined from
the dustfall collectors.  Stacked filter samplers (Cahill et al. 1976) will
be used to measure mass and size distribution of suspended particulates.
These stacked filter samplers are sufficiently portable to be operated at
various levels on the meteorological measurement towers.  Each tower will also
contain a standard hl-vol sampler at Its base, as well as a precise particle
sampler at one tower.  The specific configuration of these ambient particle
samplers will be rearranged according to tracer studies indicating the
general air motions.

     The study described will be conducted for 1 or 2 days estimated to
provide maximum emissions (strong winds, dry soils) during fall and/or spring
of 1979.

     Long-term concerns include studying the impacts on atmospheric deposition
and visibility.  We will establish, in conjunction with the Bureau of Land
Management's Craig District Office, a wet/dry deposition sampler as a part of
the NC-lAl  Atmospheric Deposition Project.   The NC-141 project Is a national
effort to collect background data describing the chemistry of deposition In a
biologically relevant format.  Concerns associated with deposition center
mainly on any changes in the basic atmospheric processes.  The atmosphere
provides most of the nutrients required for ecosystem survival (Fox 1977).
The atmospheric supply function must be analyzed and protected, particularly
with regard to revegetation.

     Visibility represents a major concern for the federal land manager.  The
program of visibility research and monitoring is only now being developed.
                                     -110-

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     Protection of visibility from deterioration by human caused sources has
been established by Congress as a national goal.  The majority of existing
information points at sulfates and nitrogen oxides as the primary cause of
reduced visibility (Latimer and Samuel son 1978) in point source plumes as
well as on a regional scale (Trijonis and Yuan 1978).

     Clearly, any suspended particulate matter smaller than 3 ym in diameter
will result In a reduction of visual range, so it Is significant to determine
this size fraction loading to the atmosphere as a result of mine activities.
We are planning to establish a long-term monitoring site at Craig (figure 1)
where visibility can be recorded along with background aerosol.  The require-
ments for visibility monitoring include three parameters:  visual range,
contrast, and chromatic!ty.  The site will include a nephelometer which
measures light scattering at the measuring point, thus giving a local measure
of the visual range.  It will also include a telephotometer measuring both
contrast and color alteration of distant targets (George and Zeller 1973).
Hopefully, this will be a long-term study so that visibility data can be
compared before and after the power plant goes on line.


                             IV.  DATA ANALYSIS

     Since a vast amount of data will be generated by these studies, it  is
important to address the problems of analysis.  The objective, as stated, for
the short-term studies will be the determination of improved emission factors
for mining activities.  Basically, two types of data will be collected from
the short-term field studies—meteorological and particulate.  The meteorol-
ogical data will be used to establish the windspeed and direction, and
stability class for each particulate event which Is measured.  The models will
be applied to all the particulate data utilizing a family of particle size as
appropriate.  By processing all the dustfall and ambient concentration data
in this fashion, we should be able to improve the emissions factors  in Table  1

     The long-term studies will provide data for Input  into national programs.
Atmospheric deposition data will be analyzed through the NC-141 system.
Various tabulations and graphical comparisons of data from all the 40-plus
sites distributed nationwide will be provided on a routine basis.  These data
will allow immediate comparison with other sites.

     Visibility data may prove to be the most difficult to analyze.  Our hope
is to develop a data base for use in evaluation of all aspects of visibility.
The data will initially be used to determine any inputs on visibility result-
ing from mining operations.   Impacts due to the growth  In town of Craig  and
due to operation of the power plant also will be investigated.
                                REFERENCES

Cahlll, T. A., L. L. Ashbaugh, J. B. Barone, R. A.  Eldred,  P. J.  Feeney,
  R. G. Flocchini, C. Goodart, D. J. Shadoan, and G. W. Wolfe.   1977.
  Analysis of respirable fractions  in atmospheric particulates via sequential
  filtration.  APCA Journal 27:675-677.
                                     -Ill-

-------
Cole, C. F., and G. E. McVehll.  1977-  Modeling participate concentrations
  and dustfall rates at the White Rocks sand and gravel mine.  p. 272-275-
  JJT_  Proc. Fourth  Int. Clean Air Congr., Union of Air Poilut. Contr. Assoc.,
  1,088 p.  [May 16-22, 1977, Tokyo, Japan.]

Fox, Douglas G.  1977.  Precipitation quality and its effects on stream water
  quality and the forest in general,  p. 103-129.  Jn.  Proc. "208" Symposium
  Non-point sources of pollution from forested land.  [Oct. 19~20, 1977,
  South. 111. Univ.]

George, David H., and Karl F. Zeller.  1973.  Visibility sensors in your air
  quality program.   Presented at Second Joint Conf. on Sensing of Environ.
  Pollutants, Instru. Soc. of Amer., Pittsburgh, Pa.  [Dec. 10-12, 1973,
  Washington, D.C.]

Gillette, D. A., R. N. Clayton, T. K. Mayeda, M. L. Jackson, and K. Sridhar.
  1978.  Tropospheric aerosols from some major dust storms of the southwestern
  United States.  J. Appl. Meteorol. 17:832-845.

Horst, Thomas W.  1977.  A surface depletion model for deposition from a
  Gaussian plume.  Atmos. Environ. 11:41-^6.

Latimer, D. A., and G. S. Samuelson.  1978.  Visual impact of plumes from
  power plants:  A theoretical model.  Atmos. Environ.  12:1^55-1^65.

Trijonls, J., and K. Yuan.  1978.  Visibility in the southwest:  An explora-
  tion of the historical data base.   U.S. EPA Rep. No. EPA 600/3-78-039
  [prepared by Technology Service Corp., April].

Van der Hoven, Isaac.  1968.  Deposition of particles and gases.  j_n_  Slade,
  David H., ed. Meteorology and Atomic Energy.  U.S. Atomic Energy Comm.
  Pub. No.  TID-24190, Oak Ridge, Tenn.
                                    -112-

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                               LIST OF SYMBOLS

   X   •  concentration,  gm/m

   a   =  vertical standard deviation of plume concentration,  m

   a   =  horizontal (perpendicular to plume)  plume concentration,  m

    u  =  mean wind speed, m/sec

x,y,z  =  orthogonal coordinates along wind direction,  perpendicular in  the
          horizontal and  vertical,  respectively.

  £,m  -  replacement variables for coordinates

a,b,c  =  coefficients (see Table 2, equation 1)

   XQ  -  a virtual source determined visually as the size of the initial
          pollutant mass distribution, m

   V.  «  effective deposition velocity, m/sec

       =a  gd2/l8v for the Stokes range of particles

          d  »  particle diameter, m

          g  «  9.8 m2/sec  =  acceleration of gravity

          v  =  kinematic viscosity of the air  -  .15 m2/sec @ 20°C

    h  *  effective plume height, m

    W  »  deposition flux, gm/m2-sec

    Q  »  source emission, gm/sec
                                      -113-

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      Table 1.--Emission factors for  individual coal mining operations
Operation
Units
Mine
A
N.W.
Colo.
Dragline lb/yd3 0.0056
Haul roads Ib/veh-mi
w/watering 6.8
no watering
B
S.W.
Wyo.
0.053
13.6
17.0
c
S.E.
Mont.
0.0030b
3.3b
D E
Cent. N.E.
N.D. Wyo.
0.021
4.3
11.2
Shovel/Truck
 loading
 coal
 overburden
                   Ib/ton
                              0.011*
0.007   0.002
0.0035
Blasting
coal
overburden
Truck dump
bottom dump
end dump
overburden
Storage pile
Drilling
coal
overburden
Fly-ash dump
Train loading
Topsoil removal
scraping
dumping
Front-end
loader
•«~^^^^^^^M«MIIIBMHM~V_^^B_B^^^^H«
lb/blast
25.1 78.1 72.4
1690 14.2 85.3
Ib/ton
0.01A 0.020 0.005 0.027
0.007.
0.002
Ib/acre-hr 1.6 u, where u is in m/sec
Ib/hole
0.22
1.5
Ib/hr 3.9
Ib/ton 0.0002
lb/yd3
0.35
0.03
Ib/ton
0.12
30n1y veh-mi  by haul  trucks; travel  by other vehicles on haul roads (pickup
 trucks,  ANFO trucks)  is incorporated into these values.

 These values were all  noted to be somehow atypical  and should not be used
 without  first determining .the limitations to their applicability described
 in this  paper.
                                      -114-

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Table 2.—Coefficients for the application of a line source Gaussian model to
          near source dispersion.  These values are only appropriate within
          10 km of the source.
     Stability
       class
         A                 0.183              0.945              0.280

         B                 0.147              0.932              0.197

         C                 0.112              0.9'l5              0.132

         D                 0.0856             0.870              0.086

         E                 0.0762             0.837              0.065

         F                 0.0552             0.816              0.042
                                       -115-

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                               POWER PLANT
    j UTAH INTERNATIONAL MINE
      AND EXPERIMENT SITE
Figure 1.—Map of vicinity of Craig,  Colorado.   Utah International  Mine,
           Colorado Ute Power Plant,  and proposed experimental  site are
           located as shown.
                                    -116-

-------
                           xx                x= tower, hi.vol
                       0.
                       •   •  •  •  •


                       •   •  •  •  •
Figure 2.--Approximate location array for samplers around stockpile.
                               -117-

-------
         OCTOBER 24, 1978
  Tuesday Morning - SESSION III

 Session Chairman:  Lyle D. Randen
                    Environmental Engineer
                    AMAX Coal Company
Tuesday Afternoon - SESSION IV

 Session Chairman:  James A. Dorsey
                    Chief, Process Measurements Branch
                    EPA/IERL-RTP
                 -119-

-------
    COMPARISON OF PREDICTED AND OBSERVED
EFFECTS OF FUGITIVE DUST FROM COAL OPERATIONS
                     by
     Alexis W.  Lemmon,  Jr.,  Ronald  Clark,
              and Duane A. Tolle

                   BATTELLE
             Columbus Laboratories
                505 King Avenue
             Columbus,  Ohio   43201
                      -121-

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                                  ABSTRACT
     In the vicinity of facilities which prepare, process, or utilize coal,
particulate emissions in the air can be measured.  This fugitive dust may be
detrimental to the environment where the quantity of particulates is great
and the concentrations of trace elements in the dust are at levels sufficiently
high to be of concern.  In the reported study, particulate concentrations were
measured experimentally in the vicinity of a mine-mouth electric generating
station.  Operations at this major power complex included coal mining, handling,
transport, and storage as well as construction and normal activities associated
with power generation.  Concentrations of elemental components of the collected
particulates have been used to predict environmental effects; the predictions
are based upon currently available values of estimated permissible concentra-
tions.   Finally, the predictions of environmental effects are compared with
results of a brief field reconnaissance of vegetation growing in the vicinity
of the power complex.
                                     -122-

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                                INTRODUCTION
     Battelle's Columbus Laboratories has contracted with the U.S.  Environ-
mental Protection Agency (U.S. EPA) to perform a comprehensive environmental
assessment of physical and chemical coal cleaning processes.   The broad goal
of this program (Contract No. 68-02-2163) is to establish a strong base of
engineering, ecological, pollution control, and cost data which can be used
to determine which coal cleaning processes are most acceptable from the
technological, environmental, and economic viewpoints.

     In order to obtain the field data necessary for the overall program,
Battelle has undertaken a sampling and analysis program designed to identify
the combinations of coal cleaning processes and environmental conditions that
are most effective in reducing the total impact of coal use on the environ-
ment.  This is being accomplished through the characterization of process
and effluent streams from a variety of coal cleaning facilities and their
associated coal transportation, storage, and refuse disposal areas.  As part
of this program, fugitive emissions in the vicinity of these operations were
measured and evaluated in terms of their potential effects on the surrounding
environments.
                             Specific Objectives

     The recent construction of an advanced coal cleaning facility at a power
complex near Homer City, Pennsylvania, provided a unique opportunity to obtain
environmental data before operation of the facility for potential comparison
with similar data to be obtained after operation would begin.  Battelle
conducted a series of pre-operational, multimedia, grab-sampling campaigns in
a study area which included this facility, in order to document the abundance
or concentrations of selected key parameters.  These data were used to evalu-
ate the air, water, and biological quality in the study area.  The pre-
operational environmental studies, while not sufficiently long-term to be a
true baseline analysis, were conducted prior to operation of the cleaning
plant as a reference point for future comparisons.

     The objective of this paper is to compare the data obtained with the
values listed in the Multimedia Environmental Goals (MEG) documents prepared
for the U.S. EPA by Research Triangle Institute (Cleland and Kingsbury, 1977a
and b).  The MEG methodology was developed to meet the need for a workable
system of evaluating and ranking pollutants for the purpose of environmental
assessment of energy-related processes.

     MEG values have been estimated for 216 pollutants by extrapolating various
toxicity data by means of simple models.  For most of these pollutants, maximum
values have been estimated for each of the three media (air, water, and land).
For each of the three media, separate maximum values have been estimated which
are considered acceptable in preventing negative effects on  (1) human health
and (2) entire ecosystems.
                                      -123-

-------
     The MEG values which are particularly appropriate for comparison with
 the environmental monitoring data Battelle collected in the area near Homer
 City are those  termed estimated permissible concentrations (EPC's).  EPC's
 are the maximum concentration of a pollutant which presents no hazard to man
 or biota on a continuous long-term basis.  These EPC values are considered
 acceptable in the ambient air, water, or soil, as appropriate, and do not
 apply to undiluted effluent streams.  The ambient application of EPC's
 corresponds to  the ambient type of sampling conducted by Battelle prior to
 operation of the Homer City Coal Cleaning Plant.  Specifically, particulate
 ambient concentrations were measured and compared with appropriate EPC's.

     A second type of MEG values considered in this paper are minimum acute
 toxicity effluent (MATE) values.  MATE's are concentrations of pollutants in
 undiluted effluent streams that will not adversely affect those persons or
 ecological systems exposed for short periods of time.  These are appropriate
 for evaluating  the potential hazards of particulates deposited on the ground
 and on vegetation in the study area.


                        Description of the Study Area

     Nearly all of Battelle's environmental monitoring was conducted within a
 study area that can be approximately bounded by a circle 4 miles (6.4 km) in
 diameter.  The  advanced coal cleaning plant in the center of the study area
 is about 2 miles (3.2 km) southwest of Homer City, Pennsylvania.

     The six major habitat types within the study area are hardwood forest,
 coniferous forest, cropland, grassland, water bodies, and areas of industrial
 development.  The forested areas are primarily hardwoods, dominated by oak
 and hickory.  Isolated pockets of pine are present as plantations rather than
 naturally-occurring species.  Cropland is extensive in the study area, including
 contour and strip-cropped fields of corn, wheat, and hay.  Grasslands include
 those areas which are presently grazed and those areas which were previously
 grazed or farmed and are now in a transition stage toward becoming a forest.

     Almost the entire study area is on top of deep mines; nearby are abandoned
 or active strip mines.  Homer City, Pennsylvania, is immediately adjacent to
 the study area  on the Northeast, and Indiana, Pennsylvania, is only 5 miles
 (8.0 km) north  of Homer City.   During Battelle's sampling campaigns, both the
 coal cleaning plant and the refuse disposal area for that facility were under
 construction in the study area.   Finally, the study area includes the Homer
 City Power Station with its associated coal storage, water treatment, and
waste disposal  facilities.

     The Homer  City Station is one part of an integrated power complex which
 includes two deep coal mines;  coal cleaning, storage, and transport facilities;
power generation facilities; and waste disposal and treatment facilities
 (Figure 1).  Coal used at the Homer City Station comes from the two dedicated
deep mines in the power complex, as well as coal hauled by truck from other
mines.   Solid refuse from power complex activities is deposited in three
different types of disposal areas, including an ash disposal area, mine waste
or "boney" piles, and the cleaning plant refuse disposal area.
                                      -124-

-------
 Ash Disposal Area
 Mine Drainage Treatment Pond
 Helvetia Boney Pile
 Coal Cleaning Plant
 Coal Storage Pile
 Power Plant
 Industrial Waste Treatment Plant
 Helen  Boney Pile
     Homer
:;:;*::* City
                                         Coal Cleaning
                                         Refuse Disposal
                                         Area
                                                                                    Kilometer
                                                                            0        0.5        1.C
FIGURE  1.  MAP OF THE STUDY AREA  SHOWING COMPONENTS  OF  THE POWER COMPLEX
                                         -125-

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                      SAMPLING AND ANALYSIS TECHNIQUES
     During the period from December 1976 through April 1977, a series of
three pre-operational, grab-sampling campaigns were conducted by Battelle in
the ambient media of the study area which included the Homer City Power Com-
plex.  These environmental monitoring studies involved sampling, laboratory
analysis, and/or evaluation of the following components of the environment:

        Fugitive dust
        Water and stream sediments
        Aquatic biota
        Terrestrial biota
        Raw coal and fly ash
        Cleaning plant refuse disposal facility
        Groundwater.

The fugitive dust data of concern in this paper were collected and analyzed
for comparison with MEG values.  The samples collected during three campaigns
were analyzed for both physical and chemical parameters.  Information from
the survey of terrestrial biota conducted during one campaign was utilized,
as later described, in attempts to confirm the results of MEG comparisons.

     Fugitive dust monitoring was conducted using high-volume (hi-vol) ambient
air samplers during the following three 48-hour sampling periods:

     •  Campaign I:  8 p.m. December 17 to 8 p.m. December 19, 1976
     •  Campaign II:  8 p.m. January 5 to 8 p.m. January 7, 1977
     •  Campaign III:  8 p.m. April 5 to 8 p.m. April 7, 1977.

The first of these three campaigns was conducted over a weekend when both coal
transfer and construction activities were low.

     A multiple-source fugitive-dust dispersion model was used to select and
verify locations for hi-vol samplers (Figure 2).  This model takes into
account such factors as wind speed, emission rate, particle size, and distance
from selected potential dust sources located within the Homer City Power
Complex.  No dust sources outside of the power complex were incorporated in
the model.  On the basis of the computer-generated diffusion-modeling results,
ten monitoring sites were established at distances of 175 to 2200 M downwind
from various local dust sources.   One of the ten sites was on private property
downwind of the power complex property and one site was on private property
upwind of the complex.

     Several potential dust sources, both local and regional, were not incor-
porated into the diffusion model for sampling site selection.  Dust generated
by vehicular traffic, parking lots, construction activities, several storage
silos, and especially the dusty surface of the plant grounds were not included
in the model due to their erratic and non-point-source nature.  Data for the
Homer City power plant stack emissions were not available in time to include
in the model.   In addition, four other major power stations (Keystone,


                                     -126-

-------
                                                       Coal Cleaning
                                                       Refuse Disposal
   Existing Ash
   Disposal Area
Coal Cleaning Plant
                                           Coal Storage Pile
                                                  CD
                                                  Power Plant
    Wind Speed and Direction
    Recorder
     Hi Vol. Sampler
FIGURE 2.   LOCATION  OF FUGITIVE  DUST  SOURCES AND  MONITORING  SITES
                                    -127-

-------
 Conemaugh,  Seward, and Shawville) are located in the same Chestnut Ridge sector
 of  the Allegheny Mountains as Homer City.  These utilities are fed from coal
 mines located either directly under or near the station sites.  The model did
 not include fugitive emission data from any of these facilities.

     Potential fugitive dust sources at the Homer City Power Complex were
 investigated during a  pre-sampling site evaluation.  Some of the dust sources
 included an ash disposal area, boney piles at both deep mines, a coal storage
 pile, road  dust, three power plant stacks, and construction-generated dust.
 The coal cleaning plant with its thermal dryers and the cleaning plant refuse
 disposal area were under construction during Battelle's sampling campaigns.
 Since these two areas were considered to be future potential sources of fugi-
 tive dust,  they were considered in the selection of sampling sites.

     In order to identify the type and quantity of pollutants being emitted
 from fugitive dust sources, a variety of analytical techniques were employed.
 Particulate mass was determined by weighing the 8 x 10-inch fiberglass filters
 used in the hi-vol samplers before and after each of the 12- or 24-hour
 sampling periods.  A microscopic analysis was made of particulates to provide
 a distinction between components such as coal dust, fly ash, pollen, or
 construction dust.  An Andersen sampling head was used on one hi-vol to obtain
 data on the distribution of particles in five size fractions.

     Particulates on the filters from the hi-vol samplers were analyzed for
 up  to 22 elements.  The analytical technique used for most elements was atomic
 absorption; but neutron activation, colorimetry, a specific ion meter, a total
 organic carbon analyzer, an LDC mercury monitor, and potentiometric titration
were also used.  Since large amounts of four of these 22 elements (Na, K, Ca,
 and Mg) were found in the blank filters, the values for these four elements
were not reported.  Four of the remaining 18 elements (Sb, Ti, V, Se) were
 analyzed only in the second or third campaign.  In general, the filter
 exhibiting  the highest percentage of coal or ash from each site was used for
analysis.   Data from 15 of the elements analyzed are compared in this paper.
                                    -128-

-------
                        COMPARISON OF ANALYTICAL DATA
                               WITH MEG VALUES
     Analytical data for fugitive dust, fly ash, and raw coal sampled in the
study area have been converted to the units used in the multimedia environ-
mental goals (MEG) study (Cleland and Kingsbury, 1977a and b).   These data
are compared with the estimated permissible concentrations (EPC's) and/or the
minimum acute toxicity effluent (MATE) values defined in the Introduction to
this paper.

     Average concentrations of 15 elements analyzed in the fugitive dust from
the study area are compared with the EPC's for air in Table 1.   Since most
of the fugitive dust appeared to emanate from the coal storage pile and
decline in concentration within 200-300 m downwind (Figure 3),  the data have
been averaged for the sampling sites located between 150-175 m and 400-1,800 m
downwind from the coal pile.  The fugitive dust concentrations for the upwind
"control" sampling location are also provided.  These field data are followed
by the appropriate maximum EPC's for air recommended for each element to
prevent negative effects to humans or the surrounding environment during
continuous long-term (chronic) exposure.  A difficulty in making comparisons
between observed and recommended levels of the 15 elements shown in Table 1
is that three EPC's for human health and 10 EPC's for the environment are
not available.

     Average concentrations for three of the elements (As, Cr, and Pb) analyzed
in fugitive dust exceeded the EPC's for human health.  These values have been
underlined in Table 1.  It is noteworthy that two of these elements (As and
Cr) had concentrations above the health-based EPC even at the upwind "control"
location.

     Maximum and minimum concentrations of  15 elements  analyzed  in fugitive
dust are compared with  the  appropriate  EPC's  for  soil  in Table 2.   Again,  the
data are grouped  to include sampling  sites  less than 200 m  (i.e.,  150-175  m)
and greater than  200 m  (i.e.,  400-1,800 m)  downwind  of  the  coal  pile.   Concen-
trations of the same elements  in  the  raw  coal are also  shown.  EPC's  for
protection of human health  and the  environment  are given for 12  elements;  no
EPC values for iron,  chlorine,  and  fluorine have  been  determined.

     The majority of  the  elements analyzed showed maximum and  frequently
minimum concentrations  in the fugitive dust that  were  far greater than the
EPC  levels suggested  for  the  soil.   Ten elements  exceeded the  EPC's for human
health and 11 elements  exceeded the EPC's for the environment.   Both the
maximum and minimum concentrations of 8 elements  (As,  Cd, Cr,  Cu, Pb, Mn,  Ni,
and  Se)  in the fugitive dust  exceeded the EPC's for both human health and the
environment.

     Obviously,  the concentrations of toxic trace elements in fugitive coal
dust  that  has settled to  the  ground does not mean tfcat these same concentra-
tions  occur  in the soil.   However,  studies involving soil contamination by
other  types  of partlculate deposition have shown that toxic trace elements
                                     -129-

-------
                             TABLE 1.   FUGITIVE DUST COMPARISONS  (yg/mj):   EPC  VALUES  FOR AIR
                                          VERSUS  HOMER CITY DATA
1
t-1
CO
o

Distance from
Coal Pile
Downwind 150-175 ra(b)
Downwind 400-1,800 m(c)
Upwind Control
EPC Category
Health
Ecology
Trace Element Concentrations, ug/m
As Cd Cr Cu Fe Pb Mn Hg Ni Ti Zn Cl

F V Se
Average Concentration in Fugitive Dust During 3 Campaigns at Homer City (24-hr Sampling Periods)
0.014 0.008 .026 0.292 3.45 0.586 0.076 0.00056 0.015 0.44 0.35^ 1.97^
0.010 0.014 .015 0.119 1.87 0.334 0.093 0.00009 0.013^0. 32 '*' 0.22 0.82
0.009 0.005 .014 0.223 1.65 0.258 0.041 0.00003 0.009 0.17(1) 0.13 1.05
Estimated Permissible Concentrations (EPC's) , yg/m
0.005 0.12(£)0.002(f)0.5 — (h) 0.36 12 16(f) 0.04(f)14 9.5
0.04^ — — — 1^ — 0.01^
5.47 ND^ 0.0049
2.03 ND 0.0026^
1.40 0.02(1) 0.0030(1)
1.2 0.5
0.1 0.03(p)
(a)  All data were  collected between December 1976 and April  1977.
(b)  Average for sampling sites 1  and 3; downwind of coal pile.
(c)  Average for sampling sites 4,  8, and 9; downwind of coal pile.
(d)  Sampling site  6; upwind of coal pile about  1600 m and off of the power station property.
(e)  From Cleland and Kingsbury (1977a and b).
(f)  Based on a Toxic Limit Value  (TLV) which recognizes the  element's carcinogenic potential
(g)  Based on teratogenic potential.
(h)  Not available.
(i)  Concentrations were not available for some  sampling sites during all three campaigns.
(j)  ND = not detectable.

-------
i
M
CO
I-"
             1300
          •2 1200
          o

          I "00
 •Cool Pile
•Site 7
                                                 Site 4
V
Boney Piles
                                                                          Site 9
                                                                             Site 8
                                               Park
                                                                                     Future
                                                                                     Coal  Refuse
                                                                                     Site
                                     500                  1000
                                             Meters From Coal Storage Pile
                                                        1500
                                                             300

                                                             250

                                                             200

                                                             150

                                                             100 £

                                                             50  ^
                                                                                    "k
                                                                                                            I
                                                         2000
                  FIGURE  3.   FUGITIVE  DUST CONCENTRATIONS COMPARED TO A TRANSECT OF THE AREA'S
                              TOPOGRAPHICAL RELIEF

-------
                           TABLE  2.   FUGITIVE  DUST COMPARISONS  (pg/g):   EPC VALUES FOR SOIL
                                        VERSUS  HOMER CITY DATA
                                                                                                               (a)
Trace Element Concentration, ug/g

As Cd Cr
Cu Fe
Pb
Mn
Hg
Concentrations in Particulate at Sampling Sites
Maximum
Minimum
Maximum
l_i Minimum
U>
Is)
Health
Ecology
Max i mum
Minimum
154 264 471
3,678 28,736
U_ JJ5 .U5 336 6,223
Concentrations in Particulate at
238 619 667
34 ND 46^
10 0.06(c) 0.
2 0.01 10
4
3
Ni
within 200
264
Ti
Zn
Cl F
m of Homer City Coal Pile (Sites 1 and
8,676
0.2 2J5 626
200 and 2,000 m of Homer
2 545.
ND ND
Concentrations
50(c>
Concentrations Determined by Individual Analysis
31 48,750
20 18,000

17
12

.3 74
35

1.1
0.34
3,563
ND
(a)
Coal Sources *
66
46
0.26 108
0.23 91
V
3)(a)
ND
ND
and 9)(S)
ND
ND
1.4
15.
65
55

Se

33
*•
122
1
2
ND
ND
(a)  Data from three sampling campaigns conducted  by Battelle in the study area.
(b)  From Cleland  and Kingsbury  (1977a and b);  all values were multiplied by 100 based on personal  communication with Kingsbury (August, 1978).
(c)  Based on carcinogenic potential.
(d)  Based on teratogenic potential.
(e)  Value not available.
(f)  SD - not detectable.
(g)  Coal sources  include:  Helen Mining Company and Helvetia Coal Company (from Upper Freeport Seam); and Trucked-in Coal  (from Lover Kittanning Se

-------
in these particulates can cause ecosystem disruption resulting in the loss of
essential nutrients and can also result in increased concentration of these
toxic elements in both plants and animals.  These types of effects have been
demonstrated for lead smelter emissions (Jackson and Watson, 1977; Kerin, 1975)
and for fly ash emissions from coal-fired power plants (Furr, et al., 1977).
Dvorak, et al. (1978), have speculated that long-term exposure to uncombusted
coal dust may cause changes in vegetation community structure similar to those
caused by particulates from coal combustion.

     Mechanisms for the movement of toxic trace elements from particulate
emissions deposited on the ground to the root zone of the soil are complex
(Vaughan, et al., 1975; Dvorak, et al., 1978).  A partial list of the factors
which influence leaching of trace elements from deposited particulates into
the soil solution include (1) the size and type of particulates,  (2) the
amount and acidity of precipitation, (3) the concentrations and physico-
chemical properties of the trace elements, (4) the texture, organic content,
pH, and other characteristics of the soil, (5) the solubility of elements into
the soil solution, and (6) the temperature of the air and soil.

     The fugitive dust quantity and composition found during monitoring has
probably been accumulating on the ground in a reasonably similar fashion since
the power plant (including the coal storage pile) began operation in 1969.
Thus, mobile elements in the settled dust may have leached into the soil.
The quantity of toxic trace elements available to vegetation, however, needs
to be determined by chemical analysis of the soil.  In spite of any leaching
of trace elements that may have increased soil concentration, the vegetation
for some distance from the coal pile has not yet shown any adverse effects
that were readily apparent during Battelle's field reconnaissance.  An analysis
of soil biota and plant diversity, however, was not conducted.

     Another basis for comparison is also possible; MATE values for components
in solid wastes have also been developed.  Inasmuch as the deposited fugitive
dusts are tantamount to being a solid waste and these deposits may contact or
be absorbed or consumed by plants and animals, comparisons with MATE values
for solid wastes would appear to be valid.  Such a comparison has been made
in Table 3.  The table's structure is similar to that of Tables 1 and 2.

     In Table 3, the appropriate MATE values are judged to be the ones related
to ecology limits.  In general, these have lower values than those for health;
exceptions are mercury (Hg), chlorine  (Cl), and fluorine (F), the latter two
for which there are no ecology values available.  Twelve of the fifteen MATE
values for health are exceeded by the maximum values for both the close-in
(<200 m) and the more remote (>200 m) sampling sites.  Eleven of  the ecology
values are exceeded.  Comparisons of solid waste MATE values with the elemen-
tal concentrations in the raw coals are also provided in Table  3.  Elemental
concentrations in the raw coal exceed many of the same elemental  EPC values
exceeded by elements in fugitive dust.  However,  the levels of  toxic elements
in the raw coal are generally lower than  the levels in the  fugitive  dust.
                                     -133-

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                          TABLE  3.   FUGITIVE  DUST COMPARISONS  (yg/g):   MATE VALUES  FOR SOLID
                                        WASTED)  VERSUS  HOMER  CITY DATA
Trace Element Concentration, ug/g
As
Cd Cr
Cu
Fe
Pb
Concentrations in Particulate at
Maximum 154
Minimum U_
264 471
18 18
3,678
336
28,736
6.223
Concentrations in Particulate at
Maximum 238
I Minimum 34
W
1
Health 50
Ecology 10

Maximum 48
Minimum 22

619 667
ND 46


10 50
0.2 50
Raw Coal
0.26 35
«0.1 30
6,061
220


1,000
IP.
57.576
11,477


300(C)
50
17,241
501
Mn Hg
Sampling Sites
632 3
65 0.2
Ni
Ti
Zn
within 200 m of Homer City
264
«
Sampling Sites Between 200 and 2,000
12.857
566

Minimum Acute
50
10
5.603 2
6 ND

545
ND

Toxicity Effluent (MATE
50 2
20 50
Concentrations Determined by Individual Analysis
31
20

48,750
18.000
17.3
12

74 1.1
35 0.34

45
2
of Three
16.8
12.8

8,676
626
m of Homer
3.007
1.356

3,563
ND(f)
Cl
Coal Pile
39,081
4,043
F V
(Sites 1 and 3)
55,000 ND
ND ND
Se

33
4
City Coal Pile (Sites, 4, 8, and 9)(a)
5.152
943.

27,278
5,806

45.600 ND
1,818 ND

122.
1

•s) for Solid Waste(b)
18,000
160
Homer City
1,329
1,125

5,000
1°.
260.000(d)
-_(e>
7,50Q(h) 500
— (C) 30
10
1
Coal Sources
66
46

0.26
0.23
108 65
91 55

ND
ND
(a)   Data from three sampling campaigns  conducted by Battelle in the study area.
(b)   From Cleland and Kingsbury (1977a and b);  all values were multiplied by 100 based on  personal communication with Kingsbury (August, 1978).
(c)   MATE values listed are for ferrous (Fe+2)_or ferric (Fe+3).
(d)   MATE value listed is for chloride ion (Cl  ).
(e)   Value not available.
(f)   ND » not detectable.
(g)   Coal sources include:  Helen Mining Company and Helvetia Coal Company (from  Upper Freeport Seam); and Trucked-in Coal (from Lower Kittanning  Sean).
(h)   MATE value listed is for fluoride ion (F~).

-------
                       CONCLUSIONS AND RECOMMENDATIONS


     Elemental concentrations in fugitive dust measured in the study area
exceeded both EPC and MATE values for air, soil quality, and solid wastes.
For example, three out of 15 elements analyzed in fugitive dust had concentra-
tions above the health-based EPC's for air quality.  Comparisons with ecology-
based EPC's for air quality, however, were very difficult due to the absence
of ten EPC values.

     Although no soil concentrations were determined, comparisons of elemental
concentrations in fugitive dust were made with ecology-based EPC's for soil
due to the potential problem of toxic elements leaching into the soil from
deposited fugitive dust.  Eleven of the 15 elements studied had concentrations
in the fugitive dust that were above the ecology-based EPC's for soil.
Twelve solid waste MATE's for health and eleven for ecology were exceeded also.
In spite of the dust (particularly coal dust) present on the ground for some
distance around the coal pile, however, the vegetation has not yet begun to
show any obvious adverse effects.

     Although applicability of EPC and MATE values are currently somewhat
limited because of known deficiencies now being corrected, the trend in these
observations appears clear.  Many trace element concentrations in the study area
are higher than desirable.  The conclusion is not, however, that immediate
corrective action is needed.  There is no obvious damage to the vegetation
even though the present conditions have evidently persisted for some time.
     Several recommendations can be made based on  this study.  First, more
field experiments are needed to validate  these results.  The amount of avail-
able data is small and more extensive  sampling and elemental analysis, parti-
cularly of soil and plant and animal  tissues, are  needed.  These  steps are
necessary to determine  the  fate of  the trace metals  in  the fugitive dust.
     Additional research also needs  to be conducted  on  EPC and MATE values  to
evaluate and rank pollutants for  the  purpose of environmental  assessment.
Much of this work was recommended  in  the  initial MEG document  (Cleland and
Kingsbury, 1977a) and is now or will  soon be in progress.  For example, MEG's
need to be related to the specific compounds or ionic forms  of an element
that are most  toxic rather  than having a  single value represent  all compounds
and ions which have a common  "parent" element.  Synergistic  and  antagonistic
effects need to be considered, because these effects may drastically  change
the hazard ranking of a pollutant  in a specific situation.   MEG's are also
needed for many of the  master parameters,  such as  the "totals" identified
by Cleland and Kingsbury  (1977a:  115)  (e.g.,  total particulates).

     In another vein,  the  comparison of trace  element  concentrations  in  fugi-
tive dust  and  MEG values  points  out the need for  laboratory  and field research,
particularly  in  relation to fugitive dust which  consists predominantly  of
coal particles.   First, the rates at which toxic  elements leach from coal  dust
into a variety of soil  types need to be explored.   Second,  the concentrations
of  toxic  elements present in the soil around a large,  open coal pile need to
be  determined  where  this pile has been in existence for a long period of time.
Third,  laboratory bioassay and long-term field studies need to be conducted
on  the  effects of coal dust on plants and animals.
                                      -135-

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                                 REFERENCES
Cleland, J. G., and G. L. Kingsbury.  1977a.  Multimedia environmental goals
  for environmental assessment, Vol. I.  Prepared for U.S. Environmental
  Protection Agency, Industrial Environmental Research Laboratory, Research
  Triangle Park, North Carolina, EPA-600/7-77-136a.

Cleland, J. G., and G. L. Kingsbury.  1977b.  Multimedia environmental goals
  for environmental assessment, Vol. II:  MEG charts and background informa-
  tion.  Prepared for U.S. Environmental Protection Agency, Industrial
  Environmental Research Laboratory, Research Triangle Park, North Carolina,
  EPA-600/7-77-136b.

Dvorak, A. J., B. G. Lewis, P. C. Ghee, E. H. Dettmann, R. F. Freeman III,
  R. M. Goldstein, R. R. Hinchman, J. D. Jastrow, F. C. Kornegay, D. L. Mabes,
  P. A. Merry, E. D. Pentecost, J. C. Prioleau, L. F. Soholt, W. S. Vinikour,
  and E. W. Walbridge.  1978.  Impacts of coal-fired power plants on fish,
  wildlife, and their habitats.  Prepared for Fish and Wildlife Service,
  U.S. Department of the Interior, Washington, D.C., FWS/OBS-78/29.

Furr, A. K., T. F. Parkinson, R. A. Hinrichs, D. R. Van Camper, C. A. Bache,
  W. H. Gutenmann, L. E. St. John, Jr., I. S. Pakkala, and D. J. Lisk.  1977.
  National survey of elements and radioactivity in fly ashes:  absorption of
  elements by cabbage grown in fly ash-soil mixtures.  Environmental Science
  and Technology, 11(13): 1194-1201.

Jackson, D. R., and A. P. Watson.  1977.  Disruption of nutrient pools and
  transport of heavy metals in a forested watershed near a lead smelter.
  Journal of Environmental Quality. 6(4): 331-338.

Kerin, Z.  1975.  Relationship between lead content in the soil and in the
  plants contaminated by industrial emissions of lead aerosols.  Pages 487-
  502.  In T. C. Hutchinson (Chief Ed.), International conference on heavy
  metals in the environment.  Vol. II,  Part 2.  Symposium was held in Toronto,
  Ontario, Canada, October 27-31, 1975.

Vaughan, B. E., K. H. Abel, D. A. Cataldo, J. M. Hales, C. E. Hane, L. A.
  Rancitelli, R. C. Routson, R. E. Wildung, and E. G. Wolf.  1975.  Review
  of potential impact on health and environmental quality from metals
  entering the environment as a result of coal utilization.  Battelle Energy
  Program Report, Battelle's Pacific Northwest Laboratories, Richland,
  Washington.
                                    -136-

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        INDUSTRIAL NON-POINT SOURCES:
        ASSESSMENT OF SURFACE RUNOFF
      FROM THE IRON AND STEEL INDUSTRY
    Gordon T. Brookman, John A. Ripp, and




          Bradford C. Middlesworth






TRC - THE RESEARCH CORPORATION OF NEW ENGLAND






           125 SILAS DEANE HIGHWAY






      WETHERSFIELD, CONNECTICUT  06109
                     -137-

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                                   ABSTRACT
     TRC - THE RESEARCH CORPORATION of New England was retained in April
1976 by the Environmental Protection Agency to assess whether surface runoff
from iron and steel mills is an environmental problem.  The program included:
       -  Identifying and characterizing sources of surface runoff unique to
          iron and steel mills.

       -  Assessing the specific problems associated with surface runoff and
          evaluating the contribution made by individual sources to the total
          problem.

       -  Identifying industry control systems which could be used to treat
          contaminated stormwater.


     TRC researched the limited existing data available, conducted plant
tours, and designed and performed a field survey at two fully integrated mills
on tidal rivers.  Data collected at the two sites indicate that the coal and
coke storage piles and the coal and coke handling areas have the highest
potential for contaminating stormwater.  The data also indicate that TSS
runoff concentrations are typical of urban runoff concentrations while TDS
values are approximately double the typical urban runoff concentrations.

     Stormwater controls which presently exist within the steel industry are
limited.  The only system specifically designed for stormwater control exists
at Armco's Houston Works where coal piles have been diked as a control measure
for both fugitive air emissions and stormwater runoff.  Some mills collect
stormwater runoff with process wastewater for subsequent treatment at a ter-
minal plant.  Those methods which are applicable to the industry include
rainfall detention ponding rings for flat roofs, swirl degritters, and reten-
tion basins or sedimentation ponds.

     TRC concluded that, with the exception of runoff from coal and coke
storage areas, stormwater runoff is not a problem when compared to point
source control.
                                     -138-

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1.0  INTRODUCTION

     Since industries and municipalities are on the way to meeting the point
source standards of the 1977 interim goal of PL 92-500 (Federal Water Pollu-
tion Control Act Amendments of 1972),  the effect of non-point source pollution
on water quality is gaining more attention.  The National Commission on Water
Quality reported in 1976 that "non-point pollutant sources are significant to
the Commission's study because they may in some instances overwhelm and negate
the reductions achieved through point  source effluent limitations."1  Based
on these findings the Commission recommended to Congress that "control or
treatment measures shall be applied to agricultural and non-point discharges
when these measures are cost-effective and will significantly help in achiev-
ing water quality standards."2

     Non-point sources are diffuse in nature, usually intermittent, site
specific, not easily monitored at their exact source, related to uncontrol-
lable meteorological events (precipitation, snow melt, drought), and not
usually repetitive in nature from event to event.  The primary transport
mechanism for non-point sources is water runoff from meteorological events.
The three basic modes of runoff transport are overland (surface) flow, inter-
flow (also called interstitial flow),  i.e., flow through the ground between
the surface and groundwater levels, and groundwater flow.  Surface runoff will
usually contain the highest quantity of contaminants and is the most rapid
method of transport of pollutants from non-point sources.

     Because of the great quantities of water and raw material used in making
iron and steel, mills are usually located near waterways.  Contaminated
stormwater runoff from these mills could rapidly reach these waterways; thus
the potential of causing a detrimental environmental impact is often present.

     In April 1976 the Metallurgical Processes Branch of the Industrial
Environmental Research Laboratory (IERL) of the Environmental Protection
Agency (EPA) at Research Triangle Park, North Carolina, retained TRC -
THE RESEARCH CORPORATION of New England to perform an assessment of surface
runoff from iron and steel mills as a task under an existing contract  (68-02-
2133).  The principal objective of this program was to provide EPA with an
evaluation which it can use in determining if stormwater runoff from iron and
steel mills is an environmental problem and should be included in the Agency's
long-term planning as an area of concern.

     The program had the following sub-objectives:


     1.   To identify sources of surface runoff unique to  iron and  steel mills
          and to characterize runoff streams in terms of quantity and
          composition.
                                     -139-

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     2.   To assess the specific problems of surface runoff at iron and
          steel mills and evaluate the contribution made by these individual
          sources to the overall problem.

     3.   To identify control systems used by the industry or by other
          industries which are or could be used to treat contaminated storm-
          water .
     This paper presents a general overview of the program with emphasis on
the field sampling portion of the program which was conducted at two iron and
steel mills.
                                     -140-

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2.0  EXISTING DATA AND IDENTIFICATION OF SURFACE RUNOFF SOURCES

     Before this program, little work had been performed on surveying storm-
water and identifying potential sources of stormwater contamination in the
steel industry.  Previously, the most comprehensive studies had been under-
taken by Armco Steel Corporation's Houston Works in Houston, Texas,^ and
Kaiser Steel's Fontana, California plant.4

     In the Armco study, the mill was divided into drainage basins, each
characterized according to size, activity, and land cover (i.e., buildings,
paved area, railroad track, undeveloped land, stockpiles, and ponds).  Each
basin was sampled for several storms.  Parameters measured included total
suspended solids (TSS), oil and grease, biochemical oxygen demand (BOD5),
total organic compound (TOG), and chemical oxygen demand (COD).

     Armco found that stormwater quantity and quality varied appreciably
with drainage basin characteristics and location.  This limited the validity
of any correlation of parameter concentrations between basins.  Furthermore,
the quality of stormwater runoff was found to vary directly with storm dura-
tion and intensity and also with the number of antecedent dry days prior to
storms.  As antecedent dry days increase, so does the potential particulate
matter to be scoured.  Other significant results of the Armco study were the
absence of a "first flush" effect, and the absence of significant quantities
of organic matter.  The  "first flush" effect is a condition where the matter
accumulated in a basin since the last runoff event is scoured from the area at
the start of the next storm event.  In almost all cases a flow dependent
effect was observed; i.e., peak parameter concentrations occurred at peak
runoff flows.

     The Kaiser program  involved sampling during the rainy  season  (February
and March) in  1975.  Runoff from twelve storm events was sampled for chloride,
conductivity,  and oil and grease.  The oil and grease results from the Kaiser
program were much higher than those obtained at Armco.

     Since the Armco and Kaiser studies were the only data  existing  on  storm-
water runoff from steel  mills, several plants were toured as  part of this
program in an  effort to  combine a number  of  factors which affect site specific
runoff, such as terrain, climate, mill locations and operations, into an
overall industry-wide assessment of the most probable sources of stormwater
contamination.  The following companies were contacted  and/or visited:
                United  States  Steel
                National Steel
                Armco Steel
                Republic Steel
                Youngstown Sheet and Tube
                Inland  Steel
                Kaiser  Steel
                CF&I Steel
                Alan Wood Steel
                                      -141-

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     Runoff from the activities and operations of steel mills was segmented
into the following groups:


       o  Runoff from storage and disposal piles (coal, coke, slag, iron).

       o  Runoff from adjacent urban areas into the mill.

       o  Runoff from slag handling and processing facilities.

       o  Runoff of accumulated materials from roof and ground areas
          from several mill operations (blast furnace, sinter plant,
          EOF shop, open hearth, coke and by-product plant, coal and coke
          handling, and finishing areas).
     Because runoff is site specific, it was impossible to compare the con-
taminated stormwater potential of an area in one particular mill to the same
area in another mill.  Climate, terrain, operations, maintenance, and the
location of processes relative to each other are unique to each mill.
Therefore, a rating system was devised which ranked the relative potential of
each activity or operation at an individual plant.  Based on the assessments
of TRC personnel, the ratings were entirely subjective, except where physical
data were available (e.g. Armco's Houston Works).  The following activities
or operations were rated as having the greatest potential for contaminating
stormwater:
       o  Coal storage piles

       o  Coke storage piles

       o  Slag dumps

       o  Iron ore and pellet storage piles

       o  Coal and coke handling
                                    -142-

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3.0  FIELD PROGRAM

     A field survey was performed at two different sites in the spring of
1977.  Both sites were fully integrated mills on tidal rivers.   The general
characteristics of each site are described in Table 1.

     Tables 2 and 3 describe the individual drainage basins sampled at Sites 1
and 2 respectively.  At Site 1, the drainage basins had been defined in pre-
vious stormwater runoff programs conducted by plant personnel.   Because there
are no well defined drainage basins within Site 2, the delineation of drainage
areas was based upon the storm sewer plans for the plant.  The storm sewer
system for Site 2 originates at the roof drains from most of the plant opera-
tions, includes the road and railroad line runoffs, and terminates in either a
canal leading into the tidal river or into the river directly.

     The general test plan for the survey was designed to determine:


     1.   Background conditions at each sampling location prior to a
          storm event, i.e., dry weather flow conditions.

     2.   Volume of stormwater runoff and pollutant concentrations in
          the runoff as a function of time for the storm event.
     The following additional data were gathered:
     1.   Rainfall accumulation as a function of time for the storm
          event.

     2.   Dustfall accumulation between storms.
     No attempt was made to assess the effects of the stormwater runoff
on the receiving water.

     The parameters measured in this survey were:
     Runoff Flow                   Rainfall
     Total Iron                    Total Suspended Solids  (TSS)
     Dissolved Iron                Total Dissolved Solids  (TDS)
     Phenols                       Cyanide
     Ammonia                       Sulfates
     Oil and  grease and organic parameters  such  as BOD5, COD and TOC were not
measured because previous work performed by TRC  showed  that these parameters
would not be  of sufficient magnitude to be  of  concern.
                                      -143-

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           TABLE 1




GENERAL SITE CHARACTERISTICS
Age of Plant
Developed Acreage
Terrain
Runoff Receiving
Body
Plant Operations
Period of Sampling
Number of Sampling
Points
Permanent Flow
Devices
Site 1
37 Years
575
Flat, Semi-Permeable
Tidal River
Coke Plant, Sinter Plant,
Blast Furnaces, Electric
Furnaces, Finishing Oper-
ations
3/77 to 4/77
5
Yes
Site 2
25 Years
3900
Flat, Permeable
Tidal River
Coke Plant, Sinter
Plant, Blast Furnaces,
Open Hearth Furnaces,
Electric Furnaces,
Finishing Operations
5/77 to 6/77
13
No
           -144-

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                     TABLE 2

DESCRIPTION OF INDIVIDUAL DRAINAGE BASINS SAMPLED
                     SITE 1
Basin
005
006
009
010
Oil
Activities and Operations
Wide Flange Mill; Shipping Office; Roundhouse (car,
truck, and railroad car repair facility) ; western
halves of the No. 1 Electric Furnace Shop, No. 2 Plate
Mill, Plate Shipping Building, Heavy Plate Shear
Building, and Plate Heat Treat Building.
Direct Reduction Plant.
West end of the Mold Foundry; area between the Coke
Plant proper and the east end of the Stock House;
Coke Transfer.
Coal transfer; main coal conveyor belt from the dock
area to the coal storage area; Coal Shaker Building;
numerous coal transfer points located in immediate
vicinity of the west end of the Coke Plant area
Mold Preparation Shop; eastern part of the No. 2
Electric Furnace Shop; eastern half of the Coke Ovens;
Coke Oven By-products area; coal pile storage area;
eastern half of the Mold Foundry; employee parking
area.
Acreage
142.8
4.6
6.6
2.6.
60.5
                     -145-

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                     TABLE 3

DESCRIPTION OF INDIVIDUAL DRAINAGE BASINS SAMPLED
                     SITE 2
Basin
002
003
004
005
006
007
008
009
010
Oil
012
013
014
Activities and Operations
Diesel Repair Shop.
Slag Filled Borrow Area; Railroad tracks.
Mold Preparation Shop; northeast side of Open Hearth
Furnaces; Railroad tracks.
South end of Open Hearth Shop; Railroad tracks; Slag
Dump Area; Mold Preparation.
Hot mills; Slab cooling area; Slab mill; Billet mill.
Hot strip mills.
Blast furnace; Sinter Plant; Employee Parking; Ore
Conveyors .
Sinter Plant; Ore Conveyors; Roadways.
One half of Open Hearth Plant; Coke Plant; Coke
yards; Numerous Railroad lines; Coke By-Products
Complex.
Coal storage.
Southern end of Coke Ovens - surface runoff.
Southern end of Coke Ovens - surface runoff.
Ladle Repair Shop; Railroad track area.
Acreage
5.5
4.8
18.6
4.0
12.0
5.2
9.1
11.4
144.6
9.9
1.3
1.5
0.6
                     -146-

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Previous work by Armco revealed very high concentrations of COD and TOC which
were concluded to be a result of inert coal and coke fines and not reactive
organics.

     The sampling sites were located in the areas of material storage and
disposal and coal and coke handling.  No slag dump runoff data were obtained
as neither site had a representative slag dump.  In addition, due to tidal
backflow problems, no iron ore or pellet storage pile runoff data were
obtained at Site 1.  The sample collection method, flow monitoring technique,
sampling schedule, and parameters to be analyzed at each of the sampling sites
within Site 1 and 2 are summarized in Tables 4 and 5 respectively.
3.1  Field Survey Results

     3.1.1  Site 1 Results

     Table 6 summarizes the storm event data for Site 1.  Of the five storm
events sampled at Site 1, only the storm of March 31 approximated the high
intensity, short duration rainfall typical of this semitropical area.  From
historical observations of previous storm events at Site 1, it was expected
that the total rainfall at various locations around the plant would differ
over the course of a storm.  This uneven distribution of rainfall was never
observed during the field program.  During the sampling program, the rainfall
was typically a steady drizzle with occasional heavy downpours uniformly
distributed over the entire plant.  In all five events, rain wedge totals
closely corresponded to the recording rain gages.

     Table 7 summarizes the flow data from Site 1.  Time-weighted average flow
data plus the range of flow for both dry and wet weather sampling are listed.
The dry weather flows at outfall 010 were not measurable; the water levels
over the weir were essentially zero except for a small trickle which volu-
me trically was negligible.  Wet flow data were limited at outfall 010 due to
occasional tidal backflows.  At outfalls 005 and Oil wet flows were signifi-
cantly higher than dry flows.  Outfall 009 showed the effects of tidal back-
flow from the river and neither samples nor flow measurements could be
obtained at the weir during any of the storm events.

     Tables 8 through 12 all refer to the pollutant data measured at Site 1.
The range (Table 8), the mean (Table 9) and the average mass loadings (Tables
10 through 12) of pollutants show the'differences between dry and wet weather
conditions.  Average mass loadings of pollutants for dry weather conditions
were calculated by multiplying the mean concentrations value measured during
each storm by the time-weighted average flows from Table 7.  Average mass
loadings for wet weather conditions were calculated by multiplying the time
weighted average concentrations by the time-weighted average flows, both
determined from the concentration and flow curves for each rainfall event.
The time weighted average wet weather flows pertain to the time over which
                                     -147-

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                   TABLE 4

SUMMARY OF SAMPLING SITES AND SAMPLING PROGRAM
                   SITE 1
OUTFALL
005
009
010
Oil
SAMPLE
COLLECTION
METHOD
I SCO Sampler
with weir
I SCO Sampler
with weir
ISCO Sampler
with weir
ISCO Sampler
with weir
FLOW
METHOD
ISCO Flow Meter
and Printer
ISCO Flow Meter
and Printer
ISCO Flow Meter
and Printer
ISCO Flow Meter
and Printer
SAMPLING
SCHEDULE FOR
STORM EVENTS
Every storm
event
Every storm
event
Every storm
event
Every storm
event
PARAMETERS
TO BE
ANALYZED
TSS, TDS
TSS, TDS, Total
Fe, Dissolved Fe,
Phenols, Cyanide,
Ammonia
TSS, TDS, Total
Fe, Dissolved Fe,
Phenols, Cyanide,
Ammonia, Sulfates
TSS, TDS, Total
Fe, Dissolved Fe,
Phenols , Cyanide ,
Ammonia
                   -148-

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                   TABLE 5

SUMMARY OF SAMPLING SITES AND SAMPLING PROGRAM
                    SITE  2
OUT? ALL
002
003
004
005
006
007
008
009
010 A
010B
Oil
012
013
014
013
SAMPLE COLLECTION
METHOD
Grab
Grab
ISCO Sampler with
weir
Grab
ISCO Sampler with
weir
ISCO Sampler with
weir
Grab
Grab
ISCO Sampler

Grab
Grab
Grab
Grab
Grab
FLOW
METHOD
Bucket and stop-
wacch
Bucket and scop-
watch
ISCO flow aetar
and printar
Suckat and stop-
wacch
ISCO Clow oacar
and prlncar
ISCO flow oatar
and printer
Nona
None
Gurley meter
Nona
Nona
None
Nona
Nona
SAMPLING
SCHEDULE FOR
STORM EVENTS
Every storm event
(whan possible)
Every storm event
(when possible)—
low priority
Sample 2 of sites
004, 006, & 007 for
each storm
Every storm event
(when possible) —
low priority
Same as 004
Same as 004
Every storm event
(when possible)
Every storm event
(whan possible)
Every storm event
Every storm event
Sample 2 of
012, 013. &
014 for each
storm
Sam* as 012
Sam* as 012
Every storm event
PARAMETERS TO BE
ANALYZED
TSS, TDS
TSS, TDS
TSS, TDS
Total Fa
Dissolved ?e
TSS, TDS
TSS, TDS
TSS, TDS
TSS, TDS
Total F*
Dissolved Fe
TSS, TDS
Total Fe
Dissolved Fe
Metals
TSS, TDS
Total Fe
Dissolved Fe
PhenoLs, Ammonia,
Cyanide
TSS, TDS, Sulfaee,
Phenols, Ammonia,
Total F*, Dis-
solved Fe, Metals
TSS, TDS, Phenols,
Sulfates, Ammonia,
Total Fa, Dis-
solved Fe, Metals,
Cyanide
TSS, TDS, Phenols,
Sulfates, Ammonia.
Total Fe, Dis-
solved Fe, Metals,
Cyanide
TSS, TDS, Total Fe
Dissolved F*
TSS, IDS, Phenols,
Sulfates, Ammonia,
Total F«, Dis-
solved Fa, Cyanide
                       -149-

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                                                      Table 6

                                                 STORM EVENT DATA
                                                      SITE  1
                                                MARCH - APRIL,  1977
Date
3/24/77
3/27-
3/28/77
3/31/77
AM/77
ft/16/77
Storm Beginning
0500
2000 (3/27)
1410
0200
0430
Storm Ending
2130
0200 (3/28)
1430
0500
2000
Total Rainfall
cm
0.84
1.42
0.20
0.36
0.71
(Inches)
(0.33)
(0.56)
(0.08)
(0.14)
(0.28)
Average
Rainfall
Intensity
cm/hr
0.05
0.23
0.61
0.13
0.05
(ln/hr)
(0.02)
(0.09)
(0.24)
(0.05)
(0.02)
Maximum
Rainfall
Intensity
cm/hr
0.13
0.61
1.07
0.41
0.56
(ln/hr)
(.05)
(0.24)
(0.42)
(0.16)
(0.22)
Ol
o

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                                   Table  7
                          DRY vs WET FLOWS
                                    SITE  1
                            MARCH -  APRIL,  1977
OUTFALL
DATE
3/24
3/27 - 28
3/29
3/31
4/4
4/5
4/16
4/18
005
M
Avg. Flow
lp.(gp.)


473
(125)


227
(60)

216
(57)
T
Rang*
lp»(gp.)


435-568
(115-150)


227
(60)

76-254
(20-67)
WET
Avg. Flow
lp«(gp>)
1056
(279)
6083
(1607)

401
(106)
2112
(558)

3456
(913)

Range
1|»(8P«>
227-2233
(60-590)
454-15026
(120-3970)

227-984
(60-260)
568-4542
(150-1200)

228-15900
(60-4200)

010
HET(W
Avg. Flow
Ip-(gp-)
12.5
(3.3)
16.0
(4.2)

HD
ND

13.3
(3.5)

Range
IpB(gjw)
0 - 29.1
(0 - 7.7)
0 - 67.0
(0 - 17.7)

ND
HD(c)

0 - 49.02
(0 - 13.0)

Oil
DR
Avg. Flow
Ipa(gpM)


38
(10)


3.4
(0.9)

87
(23)
Y
Range
lp»(gp»)


27-53
(7-14)


0-13.2
(0-3.5)

76-106
(20-28)
W
Avg. Flow
IpM(gpa)
189
(50)
708
(187)

405
(107)
170
(45)

583
(154)

ET
Range
Ipa(gpB)
45 - 534
(12-141)
38 - 2203
(10 - 582)

95-939
(25-248)
15-167
(4-97)

83-1374
(22-363)

(a)I  No flow data were  taken at Outfall* 006 and 009,  nor at the coal pile drainage ditch.
(t>)'   There was no measurable dry (low at 010 during the  progran.
(c)   NO - Ho flow data  were obtained.
(d)   Flow values are tlae  weighted average* for the entire  event.

-------
                                                                              TABLE 8

                                                             RANGE OF POLLUTANT CONCENTRATIONS AT THE
                                                                   SAMPLING LOCATIONS AT SITE 1
                                                                        MARCH - APRIL, 1977
Ul
S3
 I
Pollutant
Total Suspended Solids
Total Dissolved Solids
Total Iron
Dissolved Iron
Phenols
Cyanide (Total)
Ammonia
Sulfate
. Range of Pollutant Concentration, ng
Outfall 005
Dry
4-31
327-463






Wet
11-113
238-964






Outfall 010
Dry
4-649
2007-5438
1.1-8.3
0.1-0.6
16-34
n.d.-0.99(b)
54-96
400-1580
Wet
10-1272
661-4993
1.2-3.6
0.1-0.2
0.02-1.1
n.d.
3.6-73
180-490
I
Outfall dll
Dry
7-42
668-1049
1.1-2.7
o.io(a)
0.02-0.68
n.d.
0.57-26

Wet
9-151
427-1196
0.96-5.8
0.10-0.30
0.01-0.52
n.d.-0.01(b^
0.65-28

                            (a)
                            (b)
Only one value obtained.
n.d. - not detectable - detectable limit - 0.001 mg/t.

-------
                                                      TABLE 9



                                  MEAN POLLUTANT  CONCENTRATIONS,  IN mg/K. AT SITE 1

                                                MARCH - APRIL,  1977
Outfall
Pollutant
TSS
TDS
Total Iron
Dissolved
Iron
Phenols
Cyanide
(Total)
Ammonia
Sulfate
005
Dry
15
396






Vfet
45
541






010
Dry
84
3078
3.3
0.4
25
0.5
73
718
Wet
184
2158
2.4
0.1
0.37
-(a)
43
312
Oil
Dry
18
868
1.9
0.1
0.13
-(a)
9.1

Wet
35
919
2.6
0.2
0.086
0.002
3.4

I
I-1
in

I
       (a)
          Several non-detectable values were also obtained.

-------
             TABLE 10

AVERAGE MASS LOADINGS OF POLLUTANTS
        DRY VS. WET WEATHER
        MARCH - APRIL, 1977
       OUTFALL 005 - SITE 1
Data
Paraaatar
Total Suapandad
Solid*
Total Dlaaolvad
Solids
3/2* (Vtat)
Avg.
Cone.,
«g/l
39
938
Avg.
Flev,
lp«
(n»>
1200
(317)
1200
(317)
Avg.
HIM
Loading.
ki/hr
(Ib/hr)
2.82
(6.2)
67.5
(149)
3/27-28 (Wat)
Avg.
Cone.,
«g/l
48
332
Avg.
Flow,
Ip.
(8P-)
3845
(1016)
3847
(1016)
Avg.
Maaa
Loading,
kg/hr.
(Ib/hr)
11.1
(24.4)
76.6
(168.5)
3/29 (Dry)
Avg.
Cone.,
•8/1
16
353
Avg.
Flow,
lp»
(gpn)
473
(US)
473
(125)
Avg.
Maaa
loading,
kg/hr
(Ib/hr)
0.45
(0;99)
10.0
(22.0)
3/31 (W«e)
Avg.
Cone.,
mg/1
38
581
Avg.
Flow,
Ip.
(8P»)
401
(106)
401
(106)
Avg.
Maaa
Loading,
kg/hr
(Ib/hr)
0.91
(2.0)
14.0
(30.8)
Data
Paramatar
Total Suapandad
Sollda
Total Dlaiolvcd
Solid.
4/4 (U«e)
Avg.
Cone.,
«g/l
37
669
Avg.
Flow,
Ipit
(SI")
2434
(643)
2434
(643)
Avg.
Maaa
Loading,
kg/hr
(Ib/hr)
5.46
(12.0)
97.7
(214.9)
4/5 (Dry)
Avg.
Cone.,
•g/1
17
443
Avg.
Flow,
Ip.
(«P->
227
(60)
227
(60)
Avg.
Maaa
Loading,
kg/hr
(Ib/hr)
0.23
(0.51)
6.0
(13.2)

Avg.
Cone.,
»g/l
7S
371
4/16 (Vat)
Avg.
Flow,
lp«
(gP«)
4205
urn)
4205
(1111)
Avg.
Mesa
Loading,
kg/hr
(Ib/hr)
19.0
(41.8)
93.6
(206.0)

Avg.
Cone.,
•»/!
14
409
4/18 (Dry)
Avg.
Flow,
lp«
UP")
227
(60)
227
(60)
Avg.
Maaa
Loading,
kg/hr
(Ib/hr)
0.19
(0.42)
5.6
(12.3)
                -154-

-------
             TABLE  11

AVERAGE MASS LOADINGS OF POLLUTANTS
        DRY VS.  WET WEATHER
        MARCH -  APRIL,  1977
       OUTFALL 010  - SITE  1
Date




Parameter
Total Suspended Solids

Total Dissolved Solids

Total Iron

Dissolved Iron

Phenol

Ammonia

Sulfate

3/24 (Wet)


Avg.
Cone . ,
mg/1
76

2170

2.61



0.46

50

235


Avg.
Flow,
1pm
(gpm)
12.7
(3.36)
12.7
(3.36)
12.7
(3.36)


12.7
(3.36)
4.43
(1.17)
14.7
(3.88)
Avg.
Mass
Loading,
kg/hr
(Ib/hr)
0.06
(0.13)
1.65
(3.64)
0.002
(0.004)


0.0004
(0.0009)
0.013
(0.03)
0.25
(0.55)
3/27-28 (Wet)


Avg.
Cone . ,
mg/1
1717

150



0.119

0.559

41.0

224


Avg.
Flow,
Ipn
(gpm)
34.4
(9.1)
34.4
(9.1)


34.4
(9.1)
34.4
(9.1)
34.4
(9.1)
34.4
(9.1)
Avg.
Mass
Loading,
kg/hr
(Ib/hr)
3.54
(7.80)
0.31
(0.68)


0.0002
(0.0005)
o.ooi
(0.003-)
0.08
(0.19)
0.46
(1.02)
                  -155-

-------
                                                 TABLE 12

                                   AVERAGE  MASS LOADINGS  OF POLLUTANTS
                                            DRY VS. WET WEATHER
                                            MARCH - APRIL  1977
                                          OUTFALL Oil - SITE 1
Date




Parameter
Total
Suspended
Solids
Total
Dissolved
Solids
Total
Iron
Dissolved
Iron
Phenol

Aa*»nla

1/24 (Uet)


Avg.
.Cone.,
•g/1
11


1343


0.98*

0.1**

0.117

1.49


Avg.
Flow.
IP-
(*p->
217
(57.29)

217
(57.29)

282
(74.4)
275
72.8
262
(69.22)
252
(66.63)
Avg.
Mass
Loading.
kg/he
Ub/hr)
0.14
0.32

17. 5
(38.5)

0.02
(0.04)
0.002
(0.004)
0.002
(0.004)
0.023
(O.OS)
3/27-28 (Wet)


AVI.
Cone . i
-«/l
97


624


5.8**

0.1**

0.038

13.04


Avg.
Flow.
IP-
(CP-)
1764
(466)

1764
(466)

742
(196)
696
(184)
1669
(444)
742
(196)
AVB.
Mass
Loading,
kg/lir
(lb/hr)
10.3
(22.6)

66.0
(145.3)

0.26
(0.57)
0.004
(0.009)
0.004
(0.009)
0.58
(1.28)
3/29 (Dry)


Avg.
Cone . ,
•g/1
14


683


1.3

0.1**

0.055

22


Avg.
Flow.
Ip.
(gP->
38
(10)

38
(10)

38
(10)
38
(10)
38
(10)
38
(10)
Avg.
Haas
Loading.
kg/hr
(lb/hr)
0.03
(0.07)

1.56
(3.43)

0.003
(0.007)
0.0002
(0.0005)
0.0001
(0.0003)
O.OS
(0.11)
4/5 (Dry)


Avg.
Cone . .
•g/1
14


1021


2.6

0.1

0.26

4.9


Avg.
Flow.
IP-
(KP»)
3.4
(0.9)

3.4
(0.9)

3.4
(0.9)
3.4
(0.9)
3.4
(0.9)
3.4
(0.9)
Avg.
Haas
Loading.
kg/be
Ub/hr)
0.003
(0.007)

0.21
(0.46)

0.001
(0.002)
2.0xlO~5
(4.4xlO~5)
5.3xlO~s
(1.2xlO"s)
0.001
(0.002)
4/16 (Wet)


Avg.
Cone.,
-g/1
51


1062


3.63*

0.2*

0.08*

0.912


Avg.
Flow.
IP-
(BP-)
568
(150)

568
(150)

935
(247)
935
(247)
477
(126)
568
(150)
Avg.
Mass
Load Ing .
kg/lir
(lb/hr)
1.74
(3.83)

36.2
(79.6)

0.2
(0.45)
0.01
(0.02)
O.OO2
(0.004)
0.03
(0.07)
4/18 (Dry)


Avg.
Cone . ,
•g/1
30


785


1.9

0.1

0.025

0.97


Avg.
Flow.
IP-
(gpuO
87
(23)

87
(23)

87
(23)
87
(23)
87
(23)
87
(23)
Avg.
Mass
Loading,
kg/hr
(lb/hr)
0.16
(0.34)

4.1
(9.0)

0.01
(0.02)
0.001
(0.002)
O.O001
(0.0003)
0.005
(0.011)
 •straight average
**one value only

-------
each parameter was sampled and may vary for the different parameters within
each storm event.  In some instances, due to lack of data, straight average
concentrations (or in some cases, one data point) were used to calculate wet
weather average mass loadings.  When no flow data were measured, mass loadings
were not calculated.

     At all outfalls the mean dissolved solids were higher than the suspended
solids.  At outfalls 005, 010, and Oil, where automatic sampling was per-
formed, the dissolved solids were consistently higher than the suspended
solids, often by more than an order of magnitude.  The reaction of dissolved
solids varied with each outfall and each storm event.  However, after plotting
all the dissolved solids data and comparing these curves to the rainfall
intensity and flow curves, no conclusion can be made concerning the reaction
of dissolved solids to a storm event.

     The reaction of total suspended solids to a storm event also varied with
each outfall and event.  In a few cases, suspended solids correspond directly
to rainfall intensity and flow, but in most instances, there was a time lag
between the rainfall intensity peaks and suspended solids concentration peaks.

     The pollutant data from outfall 010 do show some interesting results.  As
indicated in Tables 8 and 9, the dry weather concentrations of total dissolved
solids, total iron, dissolved iron, phenols, cyanide, ammonia, and sulfates
were greater than the wet weather concentrations, indicating that the storm-
water runoff at outfall 010 diluted these pollutants.

     This same dilution effect was observed for phenol and ammonia concentra-
tions at outfall Oil, although the levels were much lower than those measured
at outfall 010.  The mass loading data indicate that the dry weather loading
is at least one order of magnitude less than the wet weather loading of
phenols.  In most cases the same is true for the ammonia loadings.

     From the limited data taken at outfalls 010 and Oil, the concentrations
of phenols exhibited a consistent pattern.  Increases and decreases in meas-
ured phenols loading in these drainage basins correspond directly to increases
and decreases in rainfall intensity with very little time lag.

     In most cases, ammonia showed a general trend of decreasing concentration
over the period of  the storm, indicating that the stormwater acted to dilute
the ammonia over the course of the storm rather  than cause a "first flush"
effect.  In no case was the "first flush" effect observed.
      3.1.2  Site 2 Results

      Only two  storm  events occurred during  the  field  program (May-June,  1977)
which were  of  sufficient magnitude to produce surface runoff.   Data  from these
events are  summarized  in Table  13.
                                     -157-

-------
                                                   TABLE 13

                                               STORM EVENT DATA
                                                    SITE 2
                                               MAY - JUNE, 1977

Date
6/9-
6/10/77
6/20/77

Storm Beginning
0500 (6/9)
0900

Storm Ending
1500 (6/10)
2030

Total Rainfall
cm
4.45
2.59
(inches)
(1.75)
(1.02)

Average
Rainfall
Intensity
cm/hr
0.13
0.23
(in/hr)
(0.05)
(0.09)
Maximum
Rainfall
Intensity
During Storm
cm/hr
1.42
_(a)
(in/hr)
(0.56)
_(a)
oo
          (a)
             No rainfall intensity data were collected on June 20 due to equipment failure
             and manpower constraints.

-------
     The first storm event started as a steady downpour which then tapered off
to a drizzle with occasional heavy showers.  Surface runoff was evident at all
of the sampling locations.  The rainfall intensity curve for this storm event
is shown in Figure 1 along with the flow at outfall 007.

     The second storm event was short in comparison to the first, but again
resulted in a considerable amount of surface runoff at all of the sampling
sites.  This storm was also a heavy downpour.  Due to manpower constraints and
equipment failure, very little data except total rainfall and storm duration
was gathered.

     There were also several other small storm events which resulted in 1.3 cm
of rain or less.  Because most of the plant area is semi-permeable and level,
surface runoff was not detected during any of these storms.

     Table 14 shows the average flows and ranges of flow for several of the
outfalls during dry and wet weather.  Complete information exists only for
outfalls 004, 006, and 007.

     The flow data for storm events at outfalls 004, 006, and 007 show some
interesting trends.  The flow peaks at outfalls 006 and 007 corresponded very
closely to rainfall intensity peaks with almost no time lag.  Figure 1 also
shows the hydrograph of June 9-10 for outfall 007.  At outfall 004 the time
lag between rainfall intensity peaks and flow peaks ranged from  0.5 to 3.5
hours.  The difference was probably due to the type of drainage  basin associ-
ated with each outfall.   Outfalls 006 and 007 receive stormwater either
directly from roof drains or from paved areas.  The basin which  drains to
outfall 004 is a mostly unpaved (permeable) area, causing the time lag between
rainfall peaks and runoff peaks.

     Tables 15 and 16 show the range of concentrations and the mean concentra-
tions of the pollutants analyzed at each of the outfalls for both dry and wet
weather.  Tables 17 through 19 indicate the average mass loadings of the
pollutants analyzed at outfalls 004, 006,  and 007 for both dry and wet weather
conditions.  Mass loadings were calculated in the same manner as at Site 1.

     Total dissolved solids concentrations were much higher than total sus-
pended solids concentrations at all of the outfalls during both  dry and wet
weather conditions with two exceptions, those being the wet weather concentra-
tions at outfalls 006 and Oil.  A consistent pattern was established for total
suspended solids.  A direct relationship exists between TSS concentration and
rainfall intensity corresponded directly to  an increase in TSS concentration
with no time lag.  This is shown in Figure 2.

     Several interesting  trends occurred with total and dissolved iron.  Six
out of nine outfalls showed that an increase in rainfall intensity also cor-
responded directly to an  increase in total iron concentration with no  time
lag.  This was not true of dissolved iron, since  five  out of nine outfalls
showed dissolved  iron to vary  inversely with total iron.  As total iron con-
centration decreased, dissolved iron concentration increased and vice  versa.
                                      -159-

-------
O
                                                                                                              SITE  2
                                                                                                         RAINFALL INTENSITY
                                                                                                        STORM 6/9 TO 6/10/77
                                                                                                           SITE 2
                                                                                              OUTFALL 007 STORH 6/9 TO 6/10/77
                                                                                                 TOTAL RAIKFALL  1.75 INCHES
                                                       NOON
                                                                                   TIME
                                  Figure 1:  Rainfall and Flow in Basin  007 Versus Time, Site 2, 6/9 to 6/10/77. Stora

-------
rim

-90
I   1   ,0   It
 	       WOR
                         t    i    i    10  it   t
\-iaa
                                                      TSS AVCUGC LSMtSS "All
                                                        .on 
-------
                                  TABLE 14

                             DRY VS. WET FLOWS
                                   SITE 2
                              MAY - JUNE, 1977
                                           (a)
Outfall

002 (b)
UUi


nnL^
00*


nnfi(c)
OOo


nn?(c)
007


009 (b)
(j(jy


010A(b)
ijj.vj/t


mnB
Ol'JB

Dace
5/10
5/18
6/9-10
6/20
5/10
5/18
6/9-10
6/20
5/10
5/18
6/9-10
6/20
5/10
5/18
6/9-10
6/20
5/10
5/18
6/9-10
6/20
5/10
5/18
6/9-10
6/20
5/10
5/18
6/9-10
6/20
Sampling
Condition
Dry
Dry
Wet
Wet
Dry
Dry
Wet
Wet
Dry
Dry
Wet
Wet
Dry
Dry
Wet
Wet
Dry
Dry
Wet
Wet
Dry
Dry
Wet
Wet
Dry
Dry
Wet
Wet
Average Flow
1pm (gpm)
—
53 (14)
-
-
163 (43)
413 (109)
549 (145)
382 (101)
1120 (296)
2150 (568)
2498 (660)
3066 (810)
4.5 (1.2)
2.9 (0.8)
45 (12)
291 (77)
-
5344 (1412)
-
-
_
l.OSxlO5 (28570)
-
-
_
5.14x10" (13590)
-
™
Range,
1pm (gpm)
_
23-91 (6-24)
-
-
132-310 (35-82)
223-727 (59-192)
163-988 (43-261)
189-795 (50-210)
655-3410 (173-900)
1540-3293 (407-870)
730-4290 (193-1133)
1692-9463 (447-2500)
4.0-4.9 (1.0-1.3)
2.5-4.0 (0.7-1.0)
1.1-216 (0.3-57)
45-5776 (12-1526)
-
5223-5465 (1380-1444)
-
-
_
1.03xl05-1.12xl05 (27280-29580)
-
-
_
3. 3x10" -6. 6x10" (8640-17480)
-
"*
(a)
(b)
(c)
Flow data were not collected at outfalls 003, 005, 008, Oil, 012,
013, 014, and 015.
Straight averages.
Time-weighted averages.
                                        -162-

-------
                                  TABLE 15
                  RANGE OF POLLUTANT CONCENTRATIONS AT THE
                    SAMPLING LOCATIONS AT SITE 2 IN mg/1
                              MAY - JUNE, 1977
Kl.UITAKt
Total Ju»p.nd'«
Solid*
Total DiM«lva<
Solid!
Total Iron
DUaolvad
Iron'd)
Outfill
002
On
u-29
U-2019


ttt
9-174
112-21*


00}
Dnr




U«e
11-112
93-1*8


00*
m
2-*7
113-20}
0.20-1.2
n.o.-0.2
«at
3-3»
160-339
O.U-2.2
O.l-O.l.
006
DcV
20-416
102-1J9


Vtt
B-2S37
1*5-490


007
Ort
1-40
54-245


Wat
3-119
107-411


OOJ
Orr
22-54
112-172
1.0-2.2
0.1-0.3
w«t
!»-«»
224-265
J.S-7.5
0.1-0.7
009
Drr
*-3l
114-138
0.78-1.*
0.1-0.3
Wat
55-109
151-251
3.0-5.2
0.2-0.*
KHUJTAMT
Total Suipandad
Solid.
Total Dlaaolvad
Sol Ida

Total Iran
(d)
Oliaolvad Iron
Phanel'"

Cyanidartocal)'"

A»K>nla

Sulfaca
Outfall
010A
Dry

3-37

76-123

0.37-1.3
0.1
n.d.-O.Ol

0.01

}.»-». 6


u.t

3-*»

131-253

0.91-5.9
0.1-0.4
n.d.-O.Ol

0.01

0.1-O.7


0108
Dr,

13-28

89-133
(bl
l.J
0.2
n.d.-O.Ol

n.d.-O.Ol

7.1(b)


«.t

12-702

137-239

0.74-223
n.d.-l.l
n.d.-0.06

n.d.-O.Ol

0.07-4.1


Oil
Dry














W«t

36-2694

299-691

11-23
0.2
n. a. -0.02

(c)
-
0.23-
0.43
193-270
012
Orr














Vat

29-363

222-546

1.5-26
0.1-0.6
0.01-
0.19
0.09-0.:

0.41-
1.6
52-128
013
Dry __














«at

12-1380

>33-1690

0.92-28
0.9-1.1
0.01-
0.04
0.38-
0.72
ll-ja

36-190
014
Ory














Vat

24-121

232-32*

0.9S-14
0.2-1.2







(a)
(b)
(O
(d)
(e)
(f)
No dry weather samples collected.
Only one sample analyzed.
Cyanide was not analyzed at this outfall.
n.d.-not detectable.   Detectable limit  for  dissolved  iron is 0.02 mg/1.
n.d.-noc detectable.   Detectable limit for phenol is 0.001 mg/1.
n.d.-not detectable.   Detectable limit for total cyanide is 0.001 mg/1.
                                         .  -163-

-------
                                                                                  TABLE  16



                                                            MEAN POLLUTANT CONCENTRATIONS IN  rag/1 AT SITE 2

                                                                             MAY - JUNE,  1977
 I
I-*
ON

 I

r)utt.lll
1102
DO!'"'
DO*
IK*
007
DO*
009
D10A
DID*
BU«'>
MM
»I3<">
•I4*-'

Skiing
Condition
Bry
Wet
Dry
Wet
Dry
Wet
Dry
Met
Dry
Wet
Dry
Wet
Ory
Wet
Dry
Wet
Dry
Wet
Dry
Wet
Dry
Wet
Dry
Wet
Dry
Wet

TSS
20
21
11
11
96
298
15
35
44
45
32
7)
IS
2)
19
60
831
2S7
J»2
64

•ros
749
178
no
157
216
130
223
111
227
149
241
124
201
104
18)
102
1H3
471
360
959
416

Total Iron


0.61
0.51


1.6
5.2
1.1
4.0
0.15
1.7S

-------
                                                      TABLE 17

                                       AVERAGE MASS  LOADINGS OF POLLUTANTS
                                                 DRY VS.  WET WEATHER
                                                  MAY-JUNE, 1977
                                                OUTFALL 004 - SITE 2
Ln
I
Date
•



Parameter
Total Suspended
Sol Ids
Total Dissolved
Solids
Total Iron


Dissolved Iron

5/10 (Dry)


Avg.
Cone . ,
•g/1
9

155

0.2

(b)
n.d.


Avg.
Flow,
Ip,

163
(43)
163
(43)
163
(43)

163
(43)
Avg.
Haas
Loading,
kg/hr
(Ib/hr)
0.09
(0.2)
1.5
(3.3)
0.002
(0.004)

-

5/18 (Dry)


Avg.
Cone . ,
•g/l
15

160

0.68


0.06


Avg.
Flow,
If"*

413
(109)
413
(109)
413
(109)

413
(109)
Avg.
Mass
Loading,
kg/hr
(Ib/hr)
0.37
(0.81)
4.0
(«.«)
0.02
(0.04)

0.001
(0.002)
6/9-10 (Wet)


AVR.
Cone . ,
mg/1
10

250

0.49


0.11
(0.002)

Avg-
Flow.
Ip.
(8P-)
662
(175)
662
(175)
662
(175)

693
(183)
Avg.
Mass
Loading,
kg/hr
(Ib/hr)
0.4
(0.88)
9.9
(21.8)
0.02
(0.04)

0.005
(0.011)
6/20 (Wet)


Avg.
Cone . ,
•g/1
9

203

0.36


0.04


Avg.
flow,
Ip.

401
(106)
401
(106)
401
(106)

424
(112)
Avg.
Mass
Loading,
kg/hr
(Ib/hr)
0.22
(0.48)
4.9
(10.8)
0.01
(0.02)

0.001
(0.002)
             £a'0ne value only.
             ^  'n.d.-not detectable.  Detectable limit  is 0.02 mg/1.

-------
             TABLE 18

AVERAGE MASS LOADINGS OF POLLUTANTS
        DRY VS. WET WEATHER
          MAY-JUNE, 1977
       OUTFALL 006 - SITE 2
Date
Parameter
Total Suspended
So J Ids
Total Dissolved
Solids

Avg.
Cone.,
-8/1
41
112
5/10 (Dry)
Avg.
Flow,
IP-
<*P->
1120
(296)
1120
(296)
Avg.
Mas*
Loading,
kg/hr
(Ib/hr)
2.8
(6.2)
7.5
(16.5)
5/18 (Dry)
Avg.
Cone . ,
•g/1
130
148
Avg.
riow.
IP-
(BP«>
2150
(568)
2150
(568)
Avg.
Haas
Loading,
kg/hr
(Ib/hr)
16.8
(37)
19.1
(42)
6/9-10 (Wet)
AvB.
Cone . ,
«B/l
495
244
Avg.
Flow,
IP-
«)
1851
(489)
1851
(489)
Avg.
Masa
Loading,
kg/hr
(Ib/hr)
55
(121)
27.1
(59.6)
6/20 (Wet)
Avg.
Cone. ,
•g/1
32
186
Avg.
Flow,
lp«
(8P">
2824
(746)
2824
(746)
Avg.
Mnsa
Loading,
kg/hr
(lb/l.r)
5.4
(11.9)
31.6
(69.3)

-------
             TABLE 19

AVERAGE MASS LOADINGS OF POLLUTANTS
        DRY VS. WET WEATHER
          MAY-JUNE, 1977
       OUTFALL 007 - SITE 2
Date




Parameter
Total Suspended
Solids
Total Dissolved
Solids
5/10 (Dry)


Avg.
Cone.,
•g/t
15

149


Avg.
flow.
lp-

4.5
(1.2)
4.5
(1.2)
Avg.
Haas
Loading,
kg/lir
(Ib/ht)
0.004
(0.009)
0.04
(0.09)
5/18 (Dry)


Avg.
Cone.,
•8/1
24

84


Avg.
riow.
IP-
(gp»>
2.9
(0.8)
2.9
(0.8)
Avg.
Mass
Loading.
kg/hr
Ub/hr)
0.004
(0.009)
0.01
(0.02)
6/9-10 (Wet)


Avg.
Cone.,
•g/1
36

222


Avg.
Flow,
IP-

33.3
(«.«)
33.3
(8.8)
Avg.
Haas
Loading,
kg/hr
(Ib/hr)
0.07
(0.15)
0.44
(0.97)
6/20 (Wet)


Avg.
Cone.,
•B/l
22

244


Avg.
Flow,
IP-
(gP-)
165. 4
(43.7)
165.4
(43.7)
Avg.
Haas
Loading,
kg/hr
Ub/hr)
0.22
(0.48)
2.42
(5.32)

-------
     Although there were only limited data for phenols, a pattern was observed
similar to that at Site 1.  Phenol concentration peaks were found to corres-
pond to rainfall intensity peaks.

     There appears to be no relationship between cyanide or sulfate concentra-
tion and rainfall intensity, although limited data prevent drawing any defin-
ite conclusions.  No consistent pattern exists.

     As at Site 1, ammonia concentrations tended to decrease over the period
of the storm.  Ammonia concentration peaked around the time of the first
rainfall intensity peak and then slowly decreased throughout the remainder of
the storm event.  Apparently, the stormwater dilutes the ammonia rather than
causing a "first flush" effect.   In no case was the "first flush" effect
observed.
                                    -168-

-------
4.0  SUMMARY OF FIELD RESULTS

     Based on the data collected at the two sites, the coal and coke storage
piles, and the coal and coke handling areas have the highest potential for
contaminating stormwater.  Table 20 is a summary of average concentrations of
the various pollutants in these areas for the two mills sampled.

     In order to determine the potential gross impact of stormwater runoff
from the mills sampled, the stormwater runoff mass loadings were compared to
the point source mass loadings which would exist under proposed BAT control.
Since BAT is EPA's next step in the control process (July, 1984), this com-
parison appears to be valid.

     Table 21 compares selected annual and hourly runoff mass loadings to
point source loadings based on proposed Best Available Technology (BAT)
Effluent Guidelines for TSS.  This table shows that TSS runoff loadings are
generally higher than point source loadings.  In addition to »TSS, the field
data indicate that runoff from coal piles could produce substantial mass
loadings of ammonia, phenols and total iron.

     In most cases at both sites, the parameter concentrations were rainfall
intensity dependent (i.e., the concentration increased with increased rainfall
intensity and vice versa).  In some cases, the size and characteristics of  the
drainage basin had an effect on the time lag between  rain intensity and runoff
flow, and the time lag between runoff flow and parameter concentrations.
Finally, the runoff data did not show a "first flush" effect.
                                      -169-

-------
                                       TABLE 20

                                HIGHLIGHTS  OF RESULTS
                            OF  FIELD SAMPLING PROGRAMS

                                    SITES 1 AND 2
                                  MARCH-JUNE,  1977
1
Pollutant
ISS
TBS
TOTAL
IRON
DISSOLVED
IRON


SiCa
No.
2
A
2
1
2
1
2
1
2
1
2
1
2
1
2
1
Pocaocial
Problam
Araaa
Coal Seer.
Coka Scor.
Coka » Coal
•' Handling
Coal Scor.
Coka Scor.
Coka I Coal
Handling
Coal Scor.
Coka Scar.
Coka 4 Coal
Handling
Coal Scor.
Coka Scor.
Coka i Coal
Handling
Avaraca Uac
Concancraclonat
•1/1
853
505
,„(.)
184
471
745
,„(.)
2158
18
32.3
2.4
0.2
0.09
0.12
(a)
(b)
CO.
  Thart wara Cue taapllnt polaca aaar cha coka acorafa araa ac Slca 2.  Tha avarafa concancratlon*
  for only ona (oucfall 013) ara ahovn..

  n.d. - nona dacaccad.
    .a. - noc analytad.
Pollutant
PHENOL
AMMOSU
ciums
SDLFATE


Slca
No.
2
1
2
1
2
1
2
1
2
1
2
1
2
1
2
1
Pocaaclal
Problam
Araaa
Coal Scor.
Coka Scor.
Coka t Coal
Handling
Coal Scor.
Coka Scor.
Coka t Coal
Handling
Coal Scor.
Coka Scor.
Coka 4 Coal
Handling
Coal Scor.
Coka Star.
Coka i Coal
Handling
Avarigt WaC
Coneaner aciona ,
•f/1
0.01
0.06
0.03<"
0.37
0.33
2.1
».!<•>
43
n.d."»
0.01
0.55(»>
».<.
-------
                                                                         TABLE 21


                                            COMPARISON  OF AVERAGE  ANNUAL AND HOURLY  POINT SOURCE LOADINGS WITH
                                      AVERAGE ANNUAL AND HOURLY RUNOFF LOADINGS  OF  TSS  FOR  SELECTED DRAINAGE BASINS


                                                                      SITES 1 AND 2


                                                                     March-June,  1977
•vl
M
Site
1
1
Out f .11
DOT
010
Oil
Oil
(Coal
Pile)
010
Oil
(Coal
Pile)
012
Oil
Average. Animal leading
•aaed on MT
Effluent Guideline! 3-°
Kg/yr(lfc/yr>
-
TSS 1850(4100)
TSS 1150(4100)
~— '
TSS 1.1>10S(4.0>10<>)
—
-
-
Aveiage Annual
ttinoff U»4ln( 7
(g/yrdb/yi)
TSS MOO (MOO)
TSS 80 (HO)
TSS ])1S (7290)
TSS 4.1«10*<9.0»I05)
TSS 1.5. 10 ().1«10 )
TS1 7760 (1.7.10 )
TSS 110 (HO)
TS1 150 (1110)
Average Hourly l.nadlnga
•aaed on HHX|MM< 1 Dnj
KAT Effluent Culdelloea 5
Kg/hrdk/kr)
-
TSS O.t (1.1)
TSS O.t (1.1)
—
TSS t.O (11)
—
-
-
Halnfall Ctentl
Ayeraite Naaa Loadlnga of rnllutanta In Runoff
I./hr(lb/krl
1/24/77
-
TSS 0.06(0. 11)
TSS 0.14(0.12)
—
—
-
-
-
1/27-1/28/JI
-
TSS 3.54 (7.S)
TSS 10. 1 (22.6)
~*
_
—
-
-
4/16/77
—

TSS 1.74 (J.gJ)
~
—
-
-
-
4/9-6/10/77
-
—
—
™"
TSS 21* (462)
—
-
-
4/20/77
—
_
	
"
TSS |]0 (299)
-
-
-

-------
5.0  IRON AND STEEL INDUSTRY CONTROL SYSTEMS

     Stormwater controls which presently exist within the steel industry are
limited.  The only system specifically designed for stormwater control exists
at Armco's Houston Works, where coal piles have been diked as a control
measure for both fugitive air emissions and stormwater runoff.  Runoff col-
lected within the diked area flows by gravity to an earth pond.  In nearly two
years of operation, losses from evaporation and percolation have prevented any
observed overflow from this pond.  On dry days, 190,000 liters (50,000 gal-
lons) of water (equivalent to 6 mm of rain) are sprayed on the coal piles to
control fugitive dust emissions.  This water is supplied from a separate
concrete pump basin which receives water from the blowdown of a coke plant
cooling tower.

     Several mills contacted in this program collect stormwater runoff with
process wastewater from certain mill areas and the water is subsequently
treated at a terminal plant.  This necessitates a system of combined sewers
within the plant and in several cases a holding pond is needed prior to treat-
ment to handle high flows from storms.

     Many mills store their raw materials (predominantly iron ore)  in concrete
bunkers and bins.  Some of these bunkers have concrete floors and stormwater
has to be pumped out periodically.  These bunkers were not installed for
stormwater control but rather to guard against material loss; however, they
can serve a control purpose by containing runoff which can then be pumped to a
treatment system.
                                     -172-

-------
6.0  CONCLUSIONS AND RECOMMENDATIONS

     The results of this program show that there are areas within iron and
steel mills which may pose a problem with respect to contaminated stormwater.

     From the field results at the two sites sampled we can conclude the
following:


     1.   With the exception of runoff from coal and coke storage areas, the
          majority of the basins tested in the field survey had pollutant
          discharges which, on an annual basis, were less than the proposed
          BAT Effluent Guidelines for the point sources located within the
          basins.  No data were obtained from iron ore and pellet storage
          piles and active slag dumps.

     2.   Runoff samples from the coal storage piles indicated TSS concen-
          trations to be typical of urban runoff while TDS values were
          approximately twice typical urban runoff concentrations.

     3.   At both plants, runoff from coal and coke handling areas and the
          coke plant area generated higher hourly mass loadings of total
          suspended solids than the average hourly loadings for point sources
          based on maximum 24-hour loadings in the proposed BAT Effluent
          Guidelines.

     4.   The coal storage areas sampled  in this study had much lower runoff
          concentrations for TSS, TDS, total iron, and sulfate than those
          found in runoff from utility coal containing higher percentages of
          sulfur.
     Based on  the program we recommend the following:

     1.   Site specificity should be the most  important consideration when
          evaluating  surface runoff problems at  individual plants because many
          factors affect the runoff loadings,  including:
            o  Plant  activities  and  operations
            o  Climate
            o  Soil conditions
            o  Size of  drainage  basins
            o  Location of  activities and. operations  relative  to  one  another
            o  Neighboring  industries and urban areas
            o  Proximity of plant  to receiving  waters
            o  Plant  size
                                      -173-

-------
     If stormwater runoff is found to be a problem at a specific site,
     more work should be performed to determine the feasibility of cost-
     effective controls for mill areas identified as having potential
     stormwater contamination problems.

2.   At some plants, it may be beneficial to treat stormwater from cer-
     tain areas to bring runoff mass loadings down to the same order of
     magnitude as point sources based on the proposed BAT Effluent
     Guidelines.  The most likely area is coal piles where it may be
     beneficial to treat runoff for total suspended solids, total dis-
     solved solids, and total iron.

3.   Future studies should be directed to quantify and qualify stormwater
     runoff from the iron ore storage and slag disposal areas.

4.   Because many steel plants are built on permeable soils next to
     waterways, groundwater contamination from storm events is possible.
     Future programs should investigate potential groundwater contami-
     nation from the industry.
                                -174-

-------
                                 REFERENCES
1.   Staff Report, National Commission on Water Quality (Washington, D.C.,
     April 1976).

2.   Report to the Congress. National Commission on Water Quality,
     (Washington, D.C., April 1968).

3.   Armco Steel Corporation, Houston Works, Storm Water Sampling Program
     at Armco Steel Corporation, Houston Works, Houston, Texas, April 1,
     1976.

4.   Kaiser Steel Corporation, Fontana, California, Annual Summary of
     Surface Runoff performed for the California Regional Water Quality
     Control Board, 1975.

5.   Code of Federal Regulations. Title 40 - Protection of Environment,
     Part 420 Iron and Steel Manufacturing Point Source Category, Effluent
     Guidelines and Standards as of July 1, 1976.

6.   Water Pollution Abatement Technology:  Capabilities and Cost,  Iron
     and Steel Industry, National Commission on Water Quality, November
     1975.
                                     -175-

-------
Differential Tracing of Oily Waste and the Associated
       Water Mass by Tagging with Rare Earths
                         by
                    D. L. MeGown

       Energy and Environmental Systems Division
             Argonne National Laboratory
                          -177-

-------
                                  Abstract
       A method was developed for tagging oily waste with dysprosium and the
associated fresh water with samarium.  Neutron activation analysis permitted
determination of rare earth concentrations as low as 40 ng/L in 15-mL water
samples.  Shipboard sampling procedures were developed that allowed measure-
ment of the three-dimensional distribution of the spreading wastes and associ-
ated water.  The method was applied in two field experiments that involved
tracing oily wastes and polluted water from the Indiana Harbor Canal (IHC)
into Lake Michigan.

       For a summer, floating-plume experiment, about 1400 shipboard samples
were collected.  Employment of the dual-tracer technique led to the following
results:  (.1)  after artificial mixing into the water column by a passing ship,
the tagged oil did not immediately resurface, and (2) there were no distin-
guishable differences between the movement of the oil and water over 4 km of
travel.

       During a winter, sinking-plume experiment, 1200 lake-water samples were
collected from a boat and from the raw-water intakes of Chicago's South Water
Filtration Plant (SWFP).   These data provided positive evidence of the intake
of IHC effluent and oily waste at the SWFP.  The different tracers for the
oily waste and underlying water gave evidence of separate pathways to the
SWFP, reflecting differing transport modes for surface and near-bottom waters.
                                     -178-

-------
                                INTRODUCTION
       It is important to distinguish between the dynamics of waste-receiving
waters and the motions of the associated oily wastes within and upon these
waters.  Adequate understanding of these separate but complementary motions
is essential for the development of predictive models.  A method was developed
for simultaneously tagging both oily wastes and the underlying water, each
with a unique tracer, and for determining their individual motions in fresh
water.

       Traditionally, two classes of substances have been used in tracer
studies to tag water or pollutants in water:  fluorescent dyes and radionu-
clides.  The tracing approach in the present study uses Rare Earth Element
(REE) tags and neutron-activation analysis (NAA) for tag detection.  Among
the advantages of this method are the following:

       1.  No radiation hazard to the environment exists.   ,Q
       2.  Detection of REE concentrations as low as 6 x 10    g
           in a 15-mL sample is possible.
       3.  Tracer loss to suspended matter and sediments appears
           negligible.
       4.  Rare earth element (REE) tags can be selected that are
           non-toxic to the environment.
       5.  Detection and quantification of several REE tracers
           simultaneously is simplified.

       Two tags were needed to trace simultaneously oily wastes and the waste
receiving waters.  The rare earth elements dysprosium (Dy) and samarium (Sm)
were chosen as the most suitable for the present study because

       1.  They have high detectability and short half-lives, and
       2.  Their natural occurrence in the coastal waters of Lake
           Michigan is at concentrations below the limits of detect-
           ability provided by the methods used in the present study.
           Water sample analysis (forty-eight 15-mL raw-water samples)
           showed that no natural Dy or Sm could be detected.

       Application of the tracing technique by Argonne National Laboratory
(ANL) was focused on a series of experiments conducted on the movement of
oily wastes in the coastal waters of southwestern Lake Michigan from the
Indiana Harbor Canal (IHC)(Fig. 1).  Several possible sources of oily pollu-
tants exist in the canal.  Effluents from an oil refinery, steel mills, and
municipal sewage treatment plants contain such pollutants (Snow, 1974).  Small
spills from oil transfer facilities and runoff from industrial sites also con-
tribute to the oily-waste loading.  For this study no individual source was
tagged, but rather a simulated oily waste was prepared and spilled in the
canal.

       The source of water in the IHC is Lake Michigan.  Industry draws water


                                     -179-

-------
                                                    DEPTHS  IN  FEET
                                                           METERS
                        LAKE
                     MICHIGAN
 SOUTH WATER
FILTRATION PLANT
          Fig. 1.  Location Map for Study Area and Current-Meter
                  Positions  (I-IV) in Southwestern Lake Michigan,
                                 -180-

-------
from the lake, uses the water for industrial cooling processes, and then re-
turns the water to the canal 5-8 C° warmer than the lake.  The canal water
moves into the lake as a thermal plume, sinking during much of the time in
winter, and forming a surface plume during the remainder of the year.  Signi-
ficant differences in the oil-transport regime are expected during floating-
and sinking-plume conditions.  The most difficult transport/dispersion regime
to observe in the field is that of the sinking plume, because it is difficult
to follow and sample a tagged mass of canal water that forms only a thin layer
(commonly 1- to 5-m thick) as it spreads over the bottom.  Nevertheless, the
importance of sinking-plume transport in carrying contaminants from the IHC
to municipal water intakes in southwestern Lake Michigan dictated devoting
significant efforts and resources to the tagging and tracing of IHC water
during sinking-plume conditions.

       When the wind is from the southern quadrants, during the winter sinking-
plume conditions, the City of Chicago's South Water Filtration Plant  CSWFP)
experiences periods of high hydrocarbon odors that require using expensive
activated charcoal in the treatment process.  Prior to this study, it was
thought that the odors came from IHC effluent which had migrated northwestward
along the lake bottom (Vaughan, 1970) passing over the water intakes  of the
SWFP; however, it had not been proved.  This study provides concrete  evidence
that IHC effluent enters the raw water intakes of the SWFP.
                           EXPERIMENTAL PROCEDURES

Tagging  Considerations

       Dysprosium  (Dy) was the  agent  chosen  to  tag  the  simulated  oily waste,
and  samarium (Sm)  was selected  to  tag the  IHC water.  A third  agent,  the
fluorescent  dye  rhodamine-WT, was  also used  to  tag  the  canal water  so that,
with the use of  a  pump and fluorometer, the  tagged  water mass  could be  fol-
lowed by the sampling boat.

       Waters of the IHC  are  turbid and highly  polluted.  Introduction  of an
REE  tag  into the IHC water column  in  the ionic  form would  hazard  its  removal
from solution by the formation  of  insoluble  compounds by reaction with  some of
the  many species in solution  in the IHC or on the bottom of the canal,  and
adsorption on suspended solids.

       Channell  (.1971) showed that the persistence  of lanthanum complexed with
EDTA (Ethylenediaminetetraacetic acid) in  waters that are  in contact  with
bottom sediment  is almost twice that  for lanthanum  dissolved in acid.  In view
of Channell's findings, chelation  of  REE tags was considered necessary.  The
water tracer, Sm,  was  complexed with  DTPA  (Diethylenetriaminepentaacetic acid).
DTPA was used because  it  was  cheaper  and was easier to  complex with Sm than
EDTA.

       Numerous  bench  tests  (>50)  were conducted to determine how well the
simulated  refinery/steel-mill oily waste retained the Dy tag.   The simulated
waste was  made up  of equal parts of  30-W motor  oil, #2  diesel fuel, and engine
drain oil.  The results  of the  bench  testing are discussed in detail in
McCown et  al. (1978) and  McCown et al. (1976).   A "loss factor" of
 0.4% loss  of Dy/mL of  tagged oil/mL of receiving water   was determined from
 the bench tests.

                                      -181-

-------
 Sampling Procedures

       Documentation of  transport  and mixing of a plume requires many data
 points.  This requirement dictates the removal of water samples from several
 depths and at many locations in the lake.   In addition, the position of the
 boat when samples are being taken  must be known to a high degree of accuracy.
 Therefore, a three-dimensional water-sampling system was designed that inclu-
 ded:

       1.  A Motorola Mini-Ranger  microwave ranging system interfaced
           with an x-y plotter for real-time positioning,
       2.  A fluorometer, pump, and hoses to follow the dye patch, and
       3.  A dynamically depressed faired cable with attached small
           tubes that extend to the depths  to be sampled.

       When tracking a sinking plume, an additional large tube was placed in
 the faired cable, which was used to draw bottom water samples.  A schematic
 of the sampling system, as set up  for a sinking plume, is shown in Fig. 2.

       The intermediate-depth water samples were pumped onboard, through
 4.7-mm I.D. nylon tubes, by a Masterflex multichannel tubing pump.  The flow
 rates, through =20 m of tube, was  1.67 mL/s.  This relatively low flow rate
 was sufficient because the volume  of each sample was only 15 ml.  The inter-
 mediate-depth tubes were all the same length, so that sample-removal delay
 times were equal.

       The bottom sample collected  for the  sinking-plume study was drawn
 through a 9.6-mm I.D. nylon tube, which was connected to the faired cable at
 a point 1 m above the depressor fin (Fig. 2).  The end of the bottom-sampler
 tube was connected to a 7.3 kg (16  Ib) shot that trails the depressor fin by
 »12 m so that the shot drags the bottom.  The bottom sampler had a relatively
 high flow rate of 12.5 mL/s and was driven  by a positive-displacement pump.
 Water from the bottom was fed directly to the fluorometer.  A Valved-tee at
 the fluorometer inlet directed a small portion (3.33 mL/s) of water to the
 sampling manifold for subsequent NAA at Argonne.  All the samples for NAA were
 drawn in new, 15-mL lab-grade polyethylene  Polyvials.

       In addition, a surface-skimming water sampler was built;  however, no
 acceptable means could be determined for calibrating it.  Samples drawn by
 the surface skimmer were collected  in the field, but the results of these
 samples are presented in only one instance  (see discussion on Fig. 7 in
 section on Sinking-Plume Results) as an indication of tracer presence or
absence.

       During the sinking-plume study water samples were.also drawn from the
raw-water streams of the shore and  crib intakes at the SWFP.
NAA Procedures

       The collected water samples were analyzed at ANL's CP-5 reactor.  Com-
plete details of the analytical procedures and an error analysis are discussed
in McCown et al. (1978).  The significant features of the NAA procedures,
developed at ANL, are the following:

                                     -182-

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                      MINI-RANGER  RECEIVER/TRANSMITTER
                      FOR REAL TIME  POSITIONING ON  X'Y
                      PLOTTER
                   CABLE FAIRING
)EPTH VARIES
KflTH  BOTTOM
TOPOGRAPHY
DEPTH FIXED AT
CONSTANT SPEED
                                      WATER INLET
                                  V-FIN (0.6m WING SPAN)
          Fig. 2.  Schematic  of  the  Three-Dimensional Underway Water-
                   Sampling System as Set Up for a Sinking-Plume .
                                      -183-

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       1.  No pre-Irradiation sample preparation is necessary except
           evaporation of the liquid phase and cleaning of the outside
           of the Polyvial,
       2.  The samples are irradiated in the same Polyvials in which
           they were collected,
       3.  Seventeen samples per hour can be analyzed by the method,
       4.  The per sample cost of analysis, including personnel, is
           $5.00, and                     _1                     _8
       5.  Minimum detectability of 6 x 10~   g for Dy and 2 x 10~  g
           for Sm is possible with samples of only 15 mL.

Current Measurements

       For the sinking-plume experiment, lake-current data were gathered at the
four stations (I-IV) shown on Fig. 1.  The moorings were placed in about 10 m
of water, and a Bendix Q-15R current-meter sensor was positioned about 1.5 m
above the bottom at each station; at Station I, a second meter was positioned
about 5 m above the bottom in order to obtain information on the vertical
structure of the currents.  Detailed information on current-meter mooring de-
sign, recording methods, and processing is contained in Harrison, et al. (1977),

       In-situ current-meters were not placed for the floating-plume experi-
ment because of the relatively short duration and limited horizontal extent of
the experiment.  ANL current-meters were moored offshore of the Calumet Area
for a different study so that general nearshore current information was
available.

                            RESULTS AND DISCUSSION

Floating-Plume Results

       On September 26, 1976, the IHC water was tagged in-situ with 4.5 kg
(10 Ib) of samarium that ha" been complexed with DTPA, and with 3 kg of rho-
damine WT dye.  The samarium/DPTA/Rh-WT tag was dispersed into the top meter
of IHC water by pumping the tag through a pipe with many small holes drilled
along one side.  The tagging process required 10 min and occurred in the cen-
ter of the canal at a point about 500 m from the lakeward entrance (Fig. 3).

       The Dy-tagged, simulated oily waste was poured on the surface of the
IHC effluent at the same time and in the same location as the in-situ water
tag (Sm).  The oily-waste and tracer consisted of 57 L of the waste mixed with
0.45 kg (1 Ib) of Dy.  The Dy had been dissolved in a 50% acetic acid solution.

       Shortly after tagging and before sampling had commenced, an empty ore
carrier passed directly through the center of the dye patch.   Winds on
September 26, were light from the south.   There were no significant waves,  and
the lake current was <0.05 m/s flowing to the northwest.  The plume that re-
sulted from the release of the tracers and subsequent mixing by a passing ore
carrier was mapped four times in the next 10 hr,  and over 1300  15-mL water
samples were collected.  Sampling depths  were 0.5,  1.0, 1.5,  2.5, and 3.5
meters.  About 800 of the collected water samples were analyzed by neutron
activation.  The lowest Dy concentrations that were contoured at the 0.5 m
level (80 ng/L = 200 counts)  for each of  the four plume mappings are plotted
in Fig. 3.


                                     -184-

-------
I
!-•
CO

I
                                 Fig.  3.   REE Tagging Location and Contours of Lowest Detectable
                                          Amount of Dy that was Contoured for Plume Mappings 1-4,

                                          Floating-Plume.

-------
       Table 1 lists the elapsed  time after  tagging,  the percent of the origi-
nal Dy that was accounted  for  in  each plume,  the average concentration inte-
grated over the depth, and the average dilution ratios  relative to plume 2.


       Table 1.  Floating  Plumes  1-4 Average  Concentration Parameters
Plume
1
2
3
4
Elapsed Time
After Tagging (s)
4.8 x 103
1.1 x 10k
2 x 101*
3 x 104
% Dy
Accounted For
131a
83
77
67
Average Concentration
Over the Depth (Kg/m3)
4.8 x 10~7
4.6 x 10~7
2.2 x 10~7
4.9 x 10~8
Dilution
Compared to 2
-
1:1
2:1
10:1
 High percentage due to non-synopticity of measurement.  (See text for
 explanation.)


       Diffusion coefficients were calculated using elapsed time and observed
concentration variances for the last two cloud mappings (3[K-N] and [0-R])
at the 0.5 m level.  These two mappings were in Lake Michigan proper and thus
would be subject to lake-type diffusion.  The calculated horizontal diffusion
coefficients are shown in Table 2 with appropriate values reported by Murthy
(1976) for Lake Ontario.  The values of these diffusion coefficients indicates
that our data are similar to data from the Great Lakes found using dye as the
tracer.


        Table 2.  Calculated Horizontal Diffusion Coefficients (m2/s)
      Time
                             Dy/Oil
K
K
             Sm/Water
K
K
                    Murthy's Values
K
      2.5  x 101* sec
2.2   8.4
       0.2   6.9
               1.5
                  '10.5
      aLake Ontario (dye)

       Longitudinal

      CLateral
                                     -186-

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       The percent of the Dy/oil and Sm found above 1.25 m (based on the
total amounts accounted for),  is plotted as a function of time after tracer
release in Fig. 4.  Each separate plume mapping is indicated by time in
seconds on the bottom horizontal axis.  The transition from the area protected
by the Inland Steel Landfill to the nearshore zone of Lake Michigan is indica-
ted by the vertical dashed line.
Floating-Plume Discussion

       The Dy loss factor (0.4% Dy lost/mL oil/mL water) that was determined
above may be used to estimate if significant amounts of Dy dissociated from
the oil during the floating-plume study.  The Dy is detected in plume 3 over
a volume of 1.6 x 109 L (400m x 1000m x 4m).  That volume would indicate
only a 4% loss of Dy from the oily waste.  Therefore, the loss of Dy from the
oily waste into the water through plume 3 is not thought to be significant.

       In plume 4, Dy can be detected over a volume of 6.2 x 109 L (,600m
x 1000m x 4m) for a maximum Dy loss from oil of 15%.  It is doubtful if even
a 15% loss would significantly affect the trends exhibited by the results.

       Note that the Dy tracer loss from the oily waste discussed above is
not necessarily related to the "percent Dy accounted for" in Table 1.  If
some of the Dy were lost from the oily waste, it could remain in nearby
waters and thus be sampled and detected.

       The "percent Dy accounted for" was determined by integrating the con-
centrations at sampling points over the three-dimensional structure of the
measurable plume and comparing that weight with the original amount of Dy in
the oil spilled.  Deviations from 100% are probably due to the spacing of the
grid and the diffusion of Dy to undetectable concentrations at the plume
edges.  Plume 1, which shows 131% of the original Dy accounted for appears
strange, but the seeming disparity is due to the non-synopticity of measure-
ment of that plume.  Plume 1 was sampled in a region where the flow of the
canal was relatively fast and the direction of movement was changing from
directly out of the canal to a more lakeward heading.   Consequently, measure-
ments' of plume 1 were the least synoptic of the four measured plumes.

       Figure 4 shows that the amount of Dy and Sm above 1.25 m changes with
time and horizontal position.  Both Sm  and Dy migrate  toward the surface un-
til the plume passes into the nearshore zone of Lake Michigan.  After passing
into the nearshore zone, the plume mixes downward.

       The initial movement of both tracers seems to have occurred because
warm canal water flows out and rises over the inflowing, colder Lake Michigan
water.  However, when the IHC plume enters Lake Michigan proper, it is  then
subjected to large-scale, lake-type diffusion and it is more dense than ini-
tially due to cooling.  These two factors cause the  downward migration  of  the
plume when it enters the lake proper.

       After the oily wastes were mixed into the water column,  their movement
did not differ  significantly from the underlying  Sm-tagged  waters.  As  indi-
cated above, mixing  coefficients for the Dy/oil and  Sm/water  are similar.
                                    -187-

-------
oo
oo
                   100
                   90
                o
                oc.
                   80
                    70
                    60
                                                	

                                  T    I    I   I


                                            PROTECTED  ZONE
                                          T
Dy/OIL


Sm
                   4,8 x 10'
                                            NEARSHORE

                                              ZONE
                    I.I x 10*



                   TIME (SECONDS)
2x|04        3x|04
                  Fig. 4.   Percent of the Total Dy/Oil and Sm Accounted for by Measurement

                           Found above 1.25 m vs Time after Tracer Release.

-------
Moreover, Fig. 4 indicates no significant differences in the gross vertical
movement of the Dy/oil and Sm/water.

       The above results indicate that the oily waste remained suspended in
the water column and did not float back to the surface.  The tendency for oils
to remain in suspension and not float back to the surface has also been noticed
and documented by McAuliffe (1977), Shaw (1977), Brown and Huffman (1976),
Brown and Searl (1976), Peake and Hodgson (1966, 1967), and Gordon et al. (1973)
Their results may be summarized as follows:

       1.  Under agitation, oils break up and disperse into the
           underlying waters where most remain suspended and move
           with the water, and
       2.  Colloidal particles (10~  to 10~ m) remain in suspension
           for extended periods.

       A distinct difference exists between the small, limited spill (57 L)
artificially mixed into the water column discussed in this study and a major
spill involving millions of liters.  Extrapolations from the results above to
the case of a major spill may not be valid, and different relative motions
between the oil and underlying water might be expected for a major spill.
This would be particularly true during the initial phases of spreading of a
major spill where gravity, viscosity, and surface tension are dominant.
However, when that type of slick becomes thin and oil mixes into the water
column, behavior similar to that reported in this study might be found.


Sinking-Plume Results

       On March 2, 1977, IHC water was tagged in-sitw with 13.6 kg (30 Ib) of
samarium that had been complexed with DTFA, and with 7.5 kg of rhodamine WT
dye.  The samarium/DPTA/Rh-WT tag was dispersed in the same manner as for the
floating plume.  The tagging process required 10 min and occurred at the "REE
tagging location" (Fig. 5), which  was approximately 900 m upflow from the
point where the canal water was sinking.  The zone of convergence of canal
and lake water was easily  determined with a temperature probe and is indicated
in Fig. 5 as  "surface temperature convergence."  As the survey vessel NEPTUNE
proceeded lakeward, the surface water temperature dropped from 7.5 to 1.8°C
within a few meters.  Canalward of  the sinking  zone, the water temperature was
vertically isothermal.  Just lakeward of the sinking zone, however, the
temperature profile showed warm  (=!4.00C) water  near the bottom, overlain by
colder  (*1.8°C) water.

       The Dy-tagged simulated oily waste was poured on the  surface of the
IHC effluent  at the same time and in the same location that  the in-situ water
tag (Sm) was  injected.  The oily waste and tracer consisted  of 170 L of  the
waste mixed with  1.4 kg  (3 Ib) of Dy dissolved  in a 50% acetic acid  solution.

       A progressive vector diagram of local winds and bottom currents  is
shown in Fig.  6 for the period March 1-4 for the winds and March  1-5 for
the bottom currents.   The  current meters were deployed for  this study  for the
period  January 5  to March  26,  1977. Complete details  of  the current structure
during  the period are  published  in  Harrison  et  al.  (1977).   In  summary,  major
velocity components are well-correlated within  the study  area for the  period
of measurement and suggest the  existence of  a rather  uniform flow field.

                                     -189-

-------
BOTTOM  CONTOUR
DEPTHS IN FEET
     Fig. 5.  REE Tagging Location, Temperature-Convergence Zone, and
              Positions of Sampling Transects,  Sinking-Plume.
                                    -190-

-------
12"
BOTTOM CURRENTS
(8-MIN VECTORS)
                                                  1.0 -•
MIDWAY WINDS
(8-HR VECTORS)
                                                      MAR I
                                                             MxlO
                                                        1.0
              Fig. 6.  Progressive-Vector Diagrams  for March 1-4,  1977,
                       Midway Airport Winds,  and March 1-5,  1977,  Lake
                       Michigan Bottom  Currents at  Station III (Fig.  1).
          About 1050 water  samples were  collected  in Polyvials aboard the
   NEPTUNE while  tracking the  dye that was  used  to tag the IHC effluent.   Of the
   1050  samples approximately  200 were collected in Transects A,  B,  and C (Fig.  5)
   in  the canal entrance and near entrance  areas.   All 200 were analyzed by NAA
   for their Dy and Sm concentration.  Of the remaining 800 samples  collected in
   the Calumet Harbor  area, 350 were analyzed (that is every other or every
   third sample along  a given  transect was  analyzed unless a high value was ob-
   served, in which case samples on  either  side  were analyzed) and only ten of
   those indicated the presence of Sm  (canal water); however, many of the samples
   from  the Calumet Harbor  indicated the presence  of Dy (simulated oily waste).

          All sampling transect locations are plotted on Fig. 5.   Each transect
   has an arrow indicating  the direction of boat travel, and the ends of each
   transect correspond to the  first  or last sampling station.  The distance
   between sampling stations was about 100  m.

          Figure  7 is  a plot of the  vertical Dy  concentration encountered in
   Transect A that passed directly through  the convergence'zone.   The sampling
   stations are numbered in ascending  order corresponding to the direction of
   boat  travel.   Contour values for  Dy in the figure are nanograms per liter
                                         -191-

-------
                                                TO  LAKE  MICHIGAN
                                                               LIGHT TOWER AT INDIANA
                                                               HARBOR  CANAL  ENTRANCE
                               250
VO
N>
E


CO
z

a.
LU
Q

o


Zi
Q.


CO
              10
       (BOTTOM)
                                                         10

                                           SAMPLING  STATIONS
15
                                                                                             -ENTRANCE TO
                                                                                              INDIANA HARBOR

                                                                                              TURNING BASIN
                  CONCENTRATIONS IN
                                                                                   500 meters
              Fig.  7.  Transect A:  Dy Concentrations. . (All 90 samples collected were analyzed.

                       The dashed contours indicate how the figure would look if concentration

                       values for the surface samples could have been considered.)

-------
                   _
(ng/L); that is, 10   g/L.  A region of sinking Dy/oily waste: is clearly shown
between stations 1 and 5.  The dashed contours indicate how the data would
have been contoured if data from the surface sampler were considered and
showed that some of the Dy/oil crossed the sinking, zone on the surface.

       Plots of all other transects and further explanation of the data are in
McCown et al. (1978).   In summary, all of the transects in the Calumet Harbor
area indicated fairly uniform vertical mixing of the Dy tracer.  In a number
of instances, a singular point occurred having a very high Dy concentration,
probably due to a large oil particle in the sample.

       About 240 water samples were drawn from the raw-water streams for the
shore and crib intakes at the SWFP.  These 15-mL samples were drawn every 10
min for almost all the period between 2200 hr on March 3 to 1240 hr on March 4,
1977.  From 1240 hr to 1600 hr March 4, 1977, samples were drawn every 20 min.
Water-intake samples were drawn in the same type of new 15-mL Folyvials that
were used for the shipboard samples.

       All 240 of the samples drawn at the SWFP were analyzed by NAA and those
that contained detectable Sm and/or Dy are shown on Fig. 8, a plot of relative
amounts of tracer as a function of time for each raw-water intake.  Relative
amount is computed as the amount of a given REE found in a Polyvial sample
divided by the quantity of that REE that was released in the IHC effluent
times 100.
Sinking-Plume Discussion

       Results of the winter plume-tracking field study show that the effluent
from the IHC enters the City of Chicago's water-purification system at the
SWFP's Dunne Crib and shore intakes.   (Any contaminants entering the Chicago
water system are removed at the filtration plant by activated charcoal treat-
ment, but the removal process is expensive.)  A detailed picture of the
effluent's path to the crib or shore intake cannot be established from the
tracer data because no measurements of the plume were made in the vicinity
of the intakes.  However, two paths may exist for transport of  IHC effluent
to the SWFP's water intakes.  Each path is governed by the nature of entry of
IHC effluent into the lake, incompletely mixed near-surface water taking one
path and well-mixed, 4°C bottom water  taking the other.

       During the development of a sinking plume, all of the IHC water does
not sink to the bottom when it mixes with Lake Michigan waters  at the subduc-
tion zone.  If all of it sank to the bottom, the near-surface temperatures
immediately lakeward of the convergence zone would be the same  as ambient  .
Lake Michigan water.  But temperature  profiles immediately lakeward of the
convergence zone show the near-surface water to be 1-1.5°C, not near 0°C as
is typical for ambient Lake Michigan water when ice is on the lake.  There-
fore, some portion of IHC water  (the portion that does not mix  completely)
stays near the surface and moves toward the shore due to the action of winds
blowing from the southerly quadrants.  This was the portion of  the IHC effluent
that was tracked by the NEPTUNE, and it typically follows a path  along the
shoreline.

       The other path, followed by  the portion of IHC water that  sinks to  the


                                     -193-

-------
    10"
    ID'9
    10
     .-10
   icr1
                                   Sm CRIB INTAKE
I
                                   Sm SHORE INTAKE
              I     I      I
(—
Z
cc
UJ
a.
                                   Dy  CRIB INTAKE
   10*

irr'l




1

M



(





                                  Oy SHORE INTAKE
ia«
in*




jt











•

. *







1





b









        2200   2400   0200   0400   0600   0800
                                         1000   1200   1400   1600
                                                    4
     Fig. 8.  Relative Amount of  Sm or Dy in the  Samples Collected
              at  the SWFP as a Function of Time.   (Dashed line  indi-
              cates the minimum detectable amount;  two dots at  a
              sample indicate the sample was irradiated twice and
              shows the value of  each irradiation.)
                                   -194-

-------
bottom, roughly parallels the 9.1-m (30-ft) depth contour (Fig.  1).   This iso-
bath coincides with the lakeward terminus of the IHC entrance channel.   Such
bottom water would move directly into the lake and then northwestward along
the coast, missing the area enclosed behind the Calumet Harbor Breakwater.
This sinking-plume portion of the IHC effluent would follow the second path to
travel directly to the SWFP.  Topographically, the depths of the crib intake
and of the IHC entrance channel are about the same, 9.1 m (30 ft).  Effluent
flowing out of the IHC along the bottom would tend to remain near the 9.1-m
(30-ft) contour as it moved northwestward parallel to shore, and this path
would carry it directly to the crib intake.  Further evidence of the existence
of a direct lakeward path is found in the high concentrations of Sm detected
in the crib samples and the fact that these samples were drawn at the same
time that the NEPTUNE was drawing water samples in Calumet Harbor, water
samples that contained Dy (oily waste) but virtually no Sm (canal water).

       Figure 8 shows the relative Sm amounts in the raw-water samples collect-
ed at the SWFP.  Seven of the eleven crib samples contained higher concentra-
tions of Sm than any of the eight shore samples.  Two of the crib samples
(March 3 at 2220 hr and March 4 at 0430 hr) contained very high concentrations
of Sm.  In contrast, only fourteen of the crib samples contained Dy and all
but two of these were in a three-hour-and-ten-minute span (2210-0120).  Thirty-
one of the shore samples contained Dy, however, and these were almost equally
spaced throughout the entire 17-hour sampling interval at the SWFP.

       These results indicate that significantly more Sm (the water tracer)
went to the crib intake than to the shore intake.  Also, significantly more
Dy (the oil tracer) went to the shore intake than to the crib intake.  This
appears logical because a large portion of the oily waste (Dy) would tend  to
remain on the surface and thus would be blown toward the shore by the SE
winds that occurred during the experiment.  Therefore, the oily waste would
have had a higher probability of being drawn into the shore intake.  The water
(Sm tracer), however, would be more likely to sink at the subduction zone  and
be carried along the 9.1-m  (30-ft) isobath with the prevailing northwesterly
current mentioned above; further evidence of this partitioning of the oily
waste and IHC water is found in the fact that so little Sm  (the water tag) was
seen in the Calumet Harbor area.

       A simple turbulent diffusion model was used to estimate the mixing  of
the water tag  (Sm) during the experiment.  The limited Sm data at the shore
and crib intakes and the possible partitioning of  the tag described above,
however, do not permit validation of even  the simple model proposed.  Never-
theless, a general comparison between model predictions and measured dilution
ratios at the crib intake may prove instructive.

       Table 3 presents dilution ratios  for the Sm samples  collected during
the experiment at  the SWFP's crib and shore intakes.  The dilution  ratio  is
defined as the ratio of the initial concentration  in the water at the tagging
location  to the concentration  in the collected  samples.   Initially  13.62  kg
of Sm were mixed in the IHC waters over  a  patch about  24 m  x 2 m in area  and
1 m in depth, yielding an initial concentration of 0.284  g/L.

       The mixing  of the tagged portion  of  the  IHC effluent  was  modeled in two
steps.  The dilution ratio  due  to mixing as the patch moved  from the tagging
location  out onto  the lake was modeled  first.  As  the  patch moved to the


                                     -195-

-------
       Table 3.   Sm Concentrations and Dilution Ratios for Water Samples
                 Collected  at the SWFP
Date

3 Mar.
it
4 Mar.
ti
ii
it
M
ii
ii
it
M

3 Mar.
it
ii
4 Mar.
i>
it
ii
it
Time, Concentration,
CDT yg/L :
Crib- Intake
2220
2310
0030
0300
0430
0450
0720
1040
1200
1220
1520
Shore- Intake
2200
2250
2340
0300
0450
0710
1100
1200
Raw-Water Samples
61. Ob
7.7b
2.8b
6.7b
102. lb
6.1b
2.4b
5.0b
2.1b
5.1b
1.6
Raw-Water Samples
2.9b
1.6
4.0b
1.6
1.6
2.7b
1.8
1.9
% Error

2.0
8.3
23
9.6
1.4
10
24
13
27
12
34

22
42
18
46
41
25
34
32
Dilution Ratio, —
CF

4.7 x 103
3.7 x 10"
1.0 x 105
4.2 x 10"
2.8 x 103
4.7 x 10"
1.2 x 105
5.7 x 10"
1.4 x 105
5.6 x 10"
1.8 x 105

9.8 x 10"
1.8 x 105
7.1 x 10"
1.8 x 10s
1.8 x 105
1.1 x 105
1.6 x I05
1.5 x 105
Minimum detectable amount equals 1.4 yg/L.
 Indicates average of two irradiations.
 Cj., initial concentration, equals 0.284 g/L.  CF is final concentration.
                                    -196-

-------
vicinity of the SWFP's shore and crib intakes, the dilution ratio due to
mixing in the lake was combined with the previous ratio and in addition was
calculated with a model employing 4/3's-law mixing and another employing
linear mixing.  The two models produced minimum dilution or center of patch
dilution ratios of 6.1 x 103 and 3.0 x 103 respectively in the vicinity of
the water intakes.  The exact location of the patch relative to the intakes
is unknown; however, dilution ratios calculated for the center of the patch
are of about the order of magnitude (Table 3) of those determined from
sampling at the crib and shore intakes.  Details of the models and the
coefficients used are discussed in McCown et al. (1978).
                                   SUMMARY

       A novel method was developed for simultaneous tagging of both oily
wastes and the underlying water, each with a unique tracer, and for determin-
ing their individual motions in fresh coastal waters.

       The overwater sampling aspect of the experiment required the develop-
ment of an underway three-dimensional water sampling system for the collection
of numerous 15-mL water samples.  An NAA technique permitted the analysis of
about 17 samples per hour with no pre-irradiation sample preparation other
than cleaning of the outside of the Polyvial.  The samples were collected and
subsequently irradiated in the same Polyvial.  Tracer detection limits were
6 x 10    for Dy and 2 x 10   g for Sm in the 15-mL samples.  The method was
applied to trace simulated oily waste and the underlying, polluted water from
the IHC into Lake Michigan during both the floating- and sinking-plume condi-
tions.
       The results of the floating-plume experiment indicated that:

       1.  When the tagged oil was subjected to severe downward
           mixing by a passing ore carrier, it did not resurface
           immediately but remained mixed in the water column,
       2.  Lake diffusion coefficients calculated from the Dy and Sm
           data were similar to diffusion coefficients determined by
           others in the Great Lakes using other tracer techniques,
           and
       3.  After the oil was mixed into the water column by the ore
           carrier, there were no distinguishable differences between
           the movement and diffusion of the oil/Dy and the movement
           of the water/Sm.

       The results of the sinking-plume experiment indicated  that:

       1.  IHC effluent is definitely transported to  the raw-water
           intakes of Chicago's SWFP under certain lake and meteoro-
           logical conditions,
       2.  A partitioning of the  oily wastes and underlying water
            (resulting in  separate pathways to  the SWFP's raw-water
           intakes) was made apparent by  the employment of the  dual
           tracer  system, and
       3.  Simple model estimates of  IHC  plume dilution at the  SWFP
           were  supported by the  experimental  measurements.
                                      -197-

-------
 Acknowledgments

        I would like to thank Jack Ditmars, ANL, for his careful review of the
 manuscript.  The contributions of Wyman Harrison, ANL, co-principal investi-
 gator for this study, are acknowledged as are those of the Water Resources
 Section, ANL, who helped with the field aspects of the project. , In addition,
 the assistance of the City of Chicago's Department of Water and Sewers is
 gratefully acknowledged.  This program was funded by the U.S. EPA (pass-
 through to U.S. ERDA) and the Illinois Institute for Environmental Quality.


                                 REFERENCES

 Brown, R.A. and H.L.  Huffman, Jr.,  Hydrocarbons in Open Ocean Waters,  Science
      191,  p.  847-849, 1976.

 Brown, R.A. and T.D.  Searl,  Nonvolative Hydrocarbons Along Tanker Routes of
      the Pacific Ocean,  Offshore Technology Conference 1,  p.  259-274,  1976.

 Brown, R.A.,  et al.,  Distribution of Heavy Hydrocarbons in Some Atlantic
      Ocean Waters.  Proceedings  Joint Conference on Prevention and Control
      of Oil Spills, American Petroleum Institute,  Washington, p. 505-519,
      1973.

 Channel, J.K.,  Activable Rare Earth  Elements as  Estuarine  Water Tracers,
      Ph.D.  dissertation,  Stanford University,  1971.

 Gordon,  D.C., et  al., Laboratory  Studies of the  Accommodation of Some  Crude
     and Residual Fuel Oils  in Seawater, J. Fish.  Res.  Bd.  Can., 30, p.  1611-
      1618,  1973.

 Harrison, W., D.L. McCown, L.A. Raphaelian, and  K.D.  Saunders,  Pollution of
     Coastal Waters off Chicago by Sinking Plumes  from the  Indiana Harbor
     Canal, Argonne National Laboratory Report ANL/WR-77-2, 1977.

 McAuliffe,  C.D., Dispersal and Alteration  of Oil Discharged on a Water Surface,
     Proc.  Symposium, Fate and Effects  of  Petroleum  Hydrocarbons in Marine
     Ecosystems and Organisms, Seattle, November 10-12,  1976,  D.A. Wolfe,  Ed.,
     Pergamon Press, New York, p. 19-35, 1977.

 McCown, D.L., W. Harrison and W.  Orvosh, Transport and Dispersion of Oil-
     Refinery Wastes in the  Coastal  Waters of Southwestern Lake  Michigan
     (Experimental Design — Sinking Plume Condition), Argonne National
     Laboratory Report ANL/WR-76-4,  1976.

 McCown, D.L., K.D. Saunders, J.H. Allender and J.D. Ditmars, Transport of Oily
     Pollutants in the Coastal Waters of Lake Michigan:  An Application of
     Rare Earth Tracers,  Argonne National Laboratory Report ANL/WR-78-2,
     1978 (in press).

Murthy, C.R., Horizontal Diffusion Characteristics in Lake Ontario, Journ.
     Phys.  Oceanogr.,  6(1), p. 76-84, 197.6.
                                    -198-

-------
Peake, E. and G.W. Hodgson, Alkanes in Aqueous Systems,  I,  Explanatory Investi-
     gations on the Accommodation of C  -C   n-Alkanes in Distilled Water and
     Occurrence in Natural Water Systems, j. Am. Oil Chemists' Soc., 43,
     p. 215-222, 1966.

Peake, E. and G.W. Hodgson, Alhanee in Aqueous Systems,  II, The Accommodation
     of C-J-C-. n-Alkanes in Distilled Water, J. Am Oil Chemists' Soc., 44,
     p. 696-702, 1967.

Shaw, D.G., Hydrocarbons in the Water Column, Proc. Symposium, Fate and
     Effects of Petroleum Hydrocarbons in Marine Ecosystems and Organisms,
     Seattle, November 10-12, 1976, D.A. Wolfe, Ed., Pergamon Press, New York,
     p. 8-18, 1977.

Snow, R.H., Water Pollution Investigation:  Calumet Area of Lake Michigan,
     Vols. 1 and  2 of U.S. EPA, Great Lakes Initiative Contract Prog. Kept.
     No. EPA-905/9-74-011-A, 306 pp., 1974.

Vaughan, J.C. and P.A. Reed, Progress Report on Water Quality of Lake Michi-
     gan Near Chicago, Water Sewage Works,  120(5):73-80, 1973.
                                      -199-

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                                   TP 8162
ESTIMATION OF FUGITIVE HYDROCARBON

  EMISSIONS FROM AN OIL REFINERY BY

          INVERSE MODELING
                   By

     Andrew A. Huang and Sara 3. Head

            AeroVironment Inc.
             145 Vista Avenue
         Pasadena, California 91107
                  -201-

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                                 ABSTRACT
            In order to  evaluate  an ambient air measurement approach for the
definition of fugitive emissions, the hydrocarbon emissions from an oil  refinery
were  estimated  through inverse diffusion modeling.   The AVQUAL model  was
utilized to  predict the  hydrocarbon source  terms  from the  measured  ambient
hydrocarbon  data.   The  methodology  employed  in this study is  unique in the
following ways:  (1) several source areas were handled simultaneously; (2) a tracer
gas was used to  define the meteorology on a real-time  basis; and, (3) to minimize
experimental errors an  over-specified problem  was   solved  to  determine  the
hydrocarbon emissions.

            Five different types  of hydrocarbon sources for  the  refinery were
assumed.  The  X/Q values  resulting from these sources were  computed for all
fifteen downwind receptor locations.  Subsequently, a linear programming approach
with a non-negative Q constraint was  used  to solve  for the  emission rate, Q.
Results showed qualitative agreement with direct source testing data.
                                      -202-

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1.    INTRODUCTION

     Many industrial, commercial,  and domestic  activities  emit gaseous
hydrocarbons and  other  organic  compounds  into  the atmosphere.   These
sources include all kinds of fuel  burning, solvent usage, and waste disposal
operations, as well as the more obvious chemical processing and petroleum
refining and marketing.  In the South Coast Air Basin (SCAB) of California,
petroleum  refineries contribute  a  significant  portion of the stationary
emissions of hydrocarbons.

     Refinery  hydrocarbon emissions are primarily of the  fugitive  type.
Leakage from  valves,  fittings,  flanges,  pumps, and storage  tanks,  etc.,
comprises a major portion of the emission, although some stack  emissions
result  from the  operation  of process heaters, boilers, incinerators, and
flaring.  It is impractical, if not impossible, to test all the fugitive emission
sources in  a  refinery to arrive at the emission factors.   One  approach  to
inventory the emissions is by  means of direct source testing, with emission
factors derived by statistically  combining  the results  of selective test
sources. Another approach is by ambient testing.

      An ambient  testing approach requires a workable diffusion model and
measurement of  ambient hydrocarbon levels  in the  vicinity  of a  refinery.
When  the  atmospheric  links  between emission  strength  and  ambient
concentrations are  established,  the  hydrocarbon  emission factors can  be
estimated  through inverse diffusion  modeling.  Theoretically,  the ambient
testing approach accounts  for every  emission  source  if  all  emissions  are
well-mixed, and thus provides a  more accurate' inventory in a rather simple
way. This paper  describes the methodology used in testing a refinery  in the
SCAB,  for the purpose  of evaluating a specific ambient  testing approach.
Recommendations are also presented for improving the  technique.
                               -203-

-------
 2.    TEST DESCRIPTION

      An ideal test site should be relatively compact, and reasonably distant
 from other hydrocarbon emission sources such as gas and oil wells and other
 industries so that interference would be insignificant.  Also, a heavy traffic
 flow area is not  desirable.   Furthermore, the test  refinery should  be
 representative of the refining operations in the SCAB.

      The most favorable meteorological condition for testing would include
 a  stable  atmosphere, and light  and uniform  wind fields.   This  kind  of
 condition usually  prevails in  the  early morning hours  when  drainage  flow
 exists.   Conducting testing  in  the early  morning hours has the added
 advantage  of minimum interference  from traffic emissions.   The  test site
 further requires enough downwind working space for the sampling.

      Extensive   site   survey  and  literature   research  of  the   past
 meteorological data led to the selection of a refinery located in Paramount,
 California.   Although  no direct control over the test  conditions (i.e., the
 meteorology  itself) could be exercised, it was  possible  to  select those days
 for  testing which exhibited the most favorable conditions in the refinery
 area.  This was  done through  the services of a forecaster who could predict
 when those days would most likely occur.

 2.1   Test Equipment and Approach

      To establish links  between  emissions  and  ambient concentrations, a
 tracer gas was released at the refinery.  By knowing the tracer gas releasing
 rate and the receptor point  concentrations, the source-receptor relation-
 ships could be identified through diffusion modeling.   Sulfur hexafluoride
 (SF6) was used as the tracer. This gas is ideal because  it  is inert, has very
 low  background level (<6  ppt), and can be detected down to ppt concentra-
 tion.

      Both  SF6  and hydrocarbons were measured simultaneously so that the
 relationship established for a  given period of time by the SF6 was clearly
 applicable  to the hydrocarbon case  for the same  time span.  Real time
 monitoring would have been desirable  but not practical, owing to the number
of receptors  required  (15 downwind plus 1  to  2 upwind receptors).  As an
alternative,  one-hour  integrated  samples  were taken and  immediately
analyzed by using a flame ionization detection (FID) hydrocarbon analyzer
 and  an  electron  capture detection  SF6  analyzer.   This  was possible by
 moving the AeroVironment mobile laboratory (Airlab) to the test site during
 the entire  test  period.   The  possibilities  of sample alteration were thus
 minimized.   In  addition, meteorological parameters needed  for diffusion
modeling were monitored by using instruments installed on the Airlab.  A
 mechanical weather station,  secured on the  top  of one  of the  refinery
storage tanks, served as a backup.

     Some integrated  hydrocarbon samples  were collected and sent to an
analytical  laboratory  for   analysis  by   a   gas   chromatography-mass
                               -204-

-------
spectrometry  (GC-MS).     This  way  the  hydrocarbon  concentrations
determined by different analytical means, namely FID and GC-MS, could be
correlated, and hydrocarbon speciation data obtained.

o    Ambient Air Sampling

     Two types of ambient air sampling systems  were employed:  one for
FID analyses, and one for the GC-MS analyses.  To collect samples for the
FID analyses,  ambient air was drawn  from 6 feet above ground through a
Tygon tubing and a prefilter by a Spectrex Model AS-100 gas sampling pump,
and delivered  into a 5-liter Tedlar bag.  The delivery rate was pre-set so
that at the end of the one-hour sampling period the Tedlar bag was  inflated
enough to provide the analysis needs.

     For the GC-MS analyses two samplers were used. One of the samplers
was  the  same Tedlar  bag sampler described above.   The  other  was an
adsorption sampler,  in which  an adsorption tube  filled with activated
charcoal  was used to concentrate the ambient hydrocarbons. Ambient air
was drawn from a sample point 6 feet above ground through a Tygon tubing,
the adsorption tube, a rotameter, and a  filter by a Nepture Dyna-Pump
Model  2.   After  sampling,  the exposed  adsorption tube was immediately
capped and later sent away to the laboratory as a set with the  Tedlar bag
sampled  during the  same time span.  These  bag samples were analyzed for
low  molecular weight  hydrocarbons  (C6  and below).    Adsorption  tube
samples  were analyzed  for higher  hydrocarbons (C6  and  above).   The
overlapping of C4 -  C6 from both samplers served  as a cross-check.

o    SF6 Releasing and Analyzing

     The SF6 tracer gas was  passed through a copper coil, a liquid trap, a
mass flowmeter, and a rotameter, and released into the atmosphere 28 feet
above ground. Release flowrates were measured by use of a Hastings Linear
Mass Flowmeter and continuously recorded by a strip chart recorder.

     Analysis of SF6 content in  the ambient air  sample was accomplished
by  use of an  AID Model  511 Portable Gas  Chromatograph with  electron
capture  detector.   This  instrument,  produced by  Analytical  Instrument
Development  Inc., Avondale, Pennsylvania,  was capable of detecting down
to the part per trillion (ppt) level.  Instrument calibration  was performed
before and after the instrument was used on each test day.

o    Hydrocarbon Analyzing

     A Beckman Model 6800  Air Quality Chromatograph was employed at
the study site to analyze the ambient air sample hydrocarbon  contents. This
instrument operates  on the FID  principle,  and was capable of measuring
total hydrocarbon (THC),  methane (CH«), and carbon monoxide (CO).  The
measurements of  CO content  gave  information  pertaining  to traffic
interference.
                               -205-

-------
      Instrument calibration was carried out before and after the instrument
use for each test day.  The hydrocarbon calibration gas was methane.  Thus,
THC data reported were expressed as CH4.

      FID instrument response is related not only to the concentration of the
hydrocarbon being measured,  but also to  the "effective carbon number" of
the  hydrocarbon  compound.   The  effective  hydrocarbon  number varies
depending on the number of carbon atoms  in the molecule and on the type of
compound.  Thus,  an  FID instrument calibrated with CH4 generally would
would respond to the  heavier  hydrocarbons, and the data collected could be
misleading. In order  to compensate for the deficiency, some ambient air
samples  from the vicinity of the refinery were collected  for the GC-MS
analyses. These samples were taken  side-by-side with those analyzed by the
on-site FID instrument. This approach constituted the "field calibration" for
the FID results. The GC-MS analytical results also could reveal hydrocarbon
speciation information.

o     Meteorological

      An anemometer installed 8 meters  above in the Airlab was used for
measuring  wind speed  and  wind direction.   Sigma meters were  used  to
measure  ow  and  
-------
     Testing was carried out on four days in November - December 1976.
Figure 1 illustrates the typical  receptor  locations, the SF4 release point,
and the Air lab location for a given test day. The sampler locations for GC-
MS analysis are also indicated.
                                -207-

-------
           ROSECRANS  AVE.
           Jefferson St.
                                                 LEGEND
                                                  SFg Release
                                                  Airlab
                                                  Receptor Location
                                               OSamP'er Location(GC-MS
                                                  Scale of Miles
                 ARTESIA  FREEWAY
FIGURE 1.   Schematic representation of test site for 30 November 1976.
                                -208-

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3.    DIFFUSION MODEL

     The  diffusion model used for this study was  the AVQUAL  model.
AVQUAL is a microscale diffusion model developed from Taylor's turbulent
diffusion  theory  (Taylor  1921),  which  explicitly   incorporates  ground
roughness and  heat  flux.  It  is simple and accurate.   The  presence of
inversions is accounted for.  Furthermore, this model has the capability of
simulating unsteady effects, and wind shifts can readily be incorporated.  A
detailed description of this model has been documented by Lissaman (1973).

     In the AVQUAL model, the ratio of ground level ambient concentra-
tion of a  given  receptor  point  to the source strength is a function of
meteorological conditions.   Parameters involved are  wind  speed,  wind
direction, and vertical and horizontal dispersion speeds etc. This relation-
ship is  expressed as follows:
                 n /TIT ay r2
where x   =   ambient receptor point concentration at time T
       Q   =   source strength
       u   =   mean wind speed for time span T
       x   =   receptor downwind distance from the source
       y   =   receptor crosswind distance from the source
       z   =   source height
       r2   =   x2 + y2 + z'2
       z'   =   z/A
       A   =   ratio of vertical dispersion speed to horizontal dispersion
               speed; i.e., a /a

As is evident,  x  and y are dependent on the mean wind direction for time
span T.

       For a  given test run, X,  Q,  u,  x,  y and z are  all measurable
parameters.   T is  equivalent to the time span  over  which the integrated
samples are collected.  Furthermore, A  and aw  are calculable by equating
a v to aw  and  A to av /a, where a=u • ae.  In the model validation, Q, u, x, y,
z,  A, and a   are  fed into AVQUAL to calculate  X.  The theoretical A'
values  thus  calculated  are  compared  with   the measured  A' values.
Significant  discrepancies observed between  them would indicate that the
measured meteorological data are insufficient to validate the model.  In this
case, it is necessary to carry out a model calibration.
                                 -209-

-------
 4.    TEST RESULTS AND MODEL VALIDATION/CALIBRATION RESULTS

 4.1   Test Results

      Testing was conducted on 23, 2k and 30 November, and 1 December
 1976.  Except for the 24 November  testing,  the meteorological conditions
 during the test hours were favorable.  The  atmosphere was calm with a
 stability class of E or F  (Pasquill, 1962).  Wind was generally directly from
 the  north with a wind  speed between 3-7 mph,  a typical  drainage flow
 condition in that area.   Occasionally, though, the wind would shift greatly
 and  the wind shift persisted for prolonged periods of time.  These were the
 runs which were difficult as far as model validation  was concerned.

      During the 24 November testing the atmospheric conditions were too
 calm.  There was virtually no wind most of the time. The refinery plume at
 that  time' would disperse  more  or less evenly  toward  all  directions.
 Consequently, all of the receptors  including the "upwind" one recorded about
 the same concentrations; THC was around 10 ppm, CH4 around 5 ppm, and
 SF6  around 20 ppt

      Table 1 shows  the results of successful test hours. A receptor location
 designated with "A" indicates an upwind site, while that designated with 1
 through 15 was downwind site.  There were two upwind sites for Run 15 as
 shown in Table 1.

      It is obvious  that  the  contribution from  the refinery plume to  a
 specific receptor point would be  the difference  in concentration between
 that receptor point and the upwind  point.  This  is true for  all species
 measured, namely SF6 , THC, CH4, and CO, provided that the incoming wind
 is uniform and that no  interference  is present.  These net results  will  be
 used for the  diffusion model validation/calibration,  and for the hydrocarbon
 emission predictions.

     Some of the samplers collected air samples for both FID and GC-MS
 analyses as mentioned previously.  A relationship  was established for  the
 non-methane hydrocarbons from the Douglas refinery air samples:

                    (NMHC)rr, MQ = 1.36  (NMHC)_IPk
                           VJ(^-MD             rlD

 The  correlation  factor  of 1.36 was  reasonable  considering  that the FID
 instrument was calibrated by using CH4 standards.   This correlation factor
 was eventually applied to the final  emission prediction data.

 4.2   Model Validation/Calibration  Results

     In  the model validation of AVQUAL by use of SF6, Q,  u, x, y, z, X,
and av were fed  into AVQUAL  +o  calculate X as  mentioned in  Section 3.
 The theoretical X values thus calculated were compared with  the measured
 lvalues.  S'gnificant discrepancies were observed between them,  indicating
the measured meteorological data  were insufficient  to validate the  model.
                              -210-

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TABLE 1.  Summary of test results.
            Run No: 1
         Date:  11/23/76
         Time: 0330-0430
      Wind Speed: 1.6 m/sec
     Wind Direction:  340 deg
         0  :  0,07 m/sec
           »e:  7.2 deg
           Temp:  11  C
         Stability Class: E
      Q^p : 288,960 ug/sec
        ir6
Receptor
A
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
SF6 (ppt)
3.0
6.4
3.0
1525.0
116.0
9.6
_
6.0
.
150.0
420.0
3.0
3.0
_
13.0
21.0
THC (ppm)
5.4
6.6
6.7
7.3
7.9
6.0
6.0
5.6
6.3
5.8
5.4
6.9
6.0
7.1
6.1
7.6
CH^ (ppm)
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
CO (ppm)
3.8
4.0
3.8
3.7
3.7
4.0
3.5
3.7
3.6
3.8
3.9
4.0
3.8
3.9
3.8
3.8
                -211-

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 TABLE 1. (Continued)
       Run No: 9
     Date 11/30/76
   Time:  0330-0430
 Wind Speed:  2.5 m/sec
Wind Direction: 335 deg
    a  :  0.02 m/sec
       0g : 4 deg
      Temp:  9 C
   Stability Class:  F
 Q<.p, : 299,604 pg/sec
   *C6
Receptor
A
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
SF6 (ppt)
19.5
26.0
22.5
4300.0
13.5
16.5
_
20.5
460.0
_
17.5
37.0
740.0
1010.0
16.5
17.5
THC (ppm)
5.1
6.0
6.1
9.4
9.2
5.5
6.0
5.5
7.0
5.2
5.9
5.4
6.0
6.5
5.3
6.0
CH^ (ppm)
2.6
2.6
2.5
2.6
3.2
3.0
2.6
2.5
3.0
3.0
3.1
2.8
2.6
2.8
2.9
3.0
CO (ppm)
2.5
2.8
2.2
2.3
2.5
3.3
2.3
2.1
2.8
3.1
5.2
3.2
2.5
2.5
2.9
2.6
          -212-

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 TABLE 1.  (Continued)
      Run No: 10
    Date: 11/30/76
   Time:  0430-0530
 Wind Speed:  2.0 m/sec
Wind Direction: 330 deg
     wo
0.01 m/sec
   5de
      Temp:  8VC
   Stability Class: F
 Q<-F :  299,604 yg/sec
Receptor
A
1
2
3
4
5
6
7
8
9
10
11
12
13
1*
15
SF6 (ppt)
13.5
16.0
17.5
4800.0
13.5
13.0
13.0
24.0
_
13.0
11.8
130.0
500.0
22.5
11.5
13.5
THC (ppm)
4.7
5.3
5.7
10.6
5.5
4.6
6.0
5.3
_
4.6
5.0
5.7
6.3
5.1
4.6
4.9
CH^ (ppm)
2.7
2.5
2.4
2.4
3.1
2.7
2.7
2.4
_
2.8
2.8
2.6
2.7
2.7
2.8
2.9
CO (ppm)
2.3
2.2
1.5
1.5
2.0
2.9
1.8
1.6
-
2.7
2.1
2.8
2.3
2.1
2.7
2.2
           -213-

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 TABLE 1.  (Continued)
      Run No: 11
    Date: 11/30/76
   Time:  0530-0630
 Wind Speed:  2.2 m/sec
Wind Direction: 3*0 deg
    a  :  0.01 m/sec
     woe: 4deg
      Temp:  8°C
   Stability Class:  F
 Qsp :  299,60* pg/sec
Receptor
A
1
2
3
4
5
6
7
8
9
10
11
12
13
15
SF6 (ppt)
5.6
9.8
5.6
4700.0
10.5
6.3
7.7
7.0
455.0
6.3
9.0
62.0
1200.0
425.0
9.4
THC (ppm)
4.7
6.4
5.5
7.6
10.0
4.8
5.6
4,9
7.9
4.7
4.5
5.3
6.1
6.1
4.6
CH^ (ppm)
2.6
2.4
2.3
2.4
3.1
2.6
2.7
2.5
2.4
2.6
2.6
2.6
2.4
2.6
2.6
CO (ppm)
4.1
5.0
1.9
2.4
2.7
6.6
4.5
2.3
1.1
4.8
2.0
2.7
1.8
2.5
3.1
          -214-

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 TABLE 1.  (Continued)
       Run:  15
    Date:  12/1/76
   Time:  0800-0900
 Wind Speed:  1.6 m/sec
Wind Direction: 330 deg
    a  :  0.09 m/sec
      wae  : 7 dee
      Temp: 13°X:
   Stability Class: F
 Qop :  286,220 ug/sec
   ^6
Receptor
Al
A2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
SF6 (ppt)
76.0
82.0
— t
200.0
1100.0
34.5
96.0
150.0
1400.0
71.0
450.0
480.0
_
_
480.0
500.0
498.0
THC (ppm)
5.2
6.0
7.3
7.8
6.7
5.4
6.4
6.5
7.2
6.0
6.4
6.7
OS
6.9
6.0
5.2
6.8
CH^ (ppm)
2.2
2.3
2.3
2.4
2.4
2.2
2.3
2.2
2.3
2.4
2.3
2.3
2.3
2.3
2.3
2.3
2.3
CO (ppm)
5.0
5.5
4.1
5.2
7.4
4.9
5.5
4.7
5.3
6.0
6.1
4.4
5.0
5.3
5.1
4.1
5.9
          -215-

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This was most  likely caused  by the nonrepresentativeness  of the Airlab
meteorological measurements.  Specifically, the meteorological conditions
at  the  SF6 release  location were  different  from those observed  at  the
Airlab.   This  is understandable because  the  refinery  facilities, such  as
storage tanks, cooling towers,  and  fractionation towers etc.,  could cause
slight wind direction changes and more horizontal mixing.   Perhaps more
important is the fact that the refinery operation's heat output would create
significantly more vertical mixing than what was observed at the Airlab.   As
a result, development of diffusion factors empirically by model calibration
was necessary.

     In  the  model  calibration, mean  wind  direction, X ,  and av were
determined by trial and error to minimize the difference between predicted
and measured  values of SF6. The other parameters such as Q, u, and z were
influenced by the refinery operations and thus the measured data were used.
Table 2  shows the comparison of the  measured and calibrated meteoro-
logical  data   for  the test  runs where  satisfactory agreement  between
predicted and  measured SF6  data could  be obtained. Figure 2 illustrates  the
typical  predicted  SF6 isopleths and  SF6  concentrations at  each  receptor
point for each calibrated run. Also given is the measured SF6 concentration
at each receptor point for comparison purposes.

     The calibrated mean wind direction was consistently greater than  the
measured value  by 15 to 25  degrees, as shown in Table 2.  The calibrated
values of both av and X were approximately two orders of magnitude larger
ttVan the measured values.  Since X  is the ratio of av to a, it  follows that
only av, the  vertical dispersion speed, was significantly  impacted  by  the
refinery operations; whereas  a,  the horizontal  dispersion speed, was in  the
same order of magnitude as was observed in the Airlab.  Thus, it is possible
that had the meteorological instruments been installed near the  SF6 release
point within the refinery complex the AVQUAL model would have validated
satisfactorily using the measured meteorological data.

     The model calibration factors listed in Table 2 were used directly  for
the hydrocarbon emission predictions in the following section.
                              -216-

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            Observed


            Predicted
Run:          9
Date:         11/30
Hour:         0330-0430
Wind Speed:    2.5 (rn/sec)
Wind Direction: 355 (deg)
Stability Class: F
Source Strength: 29960"+ (pg/sec)
      50   100m
                0.10

               (O.Oi
0.10
    FIGURE 2.   Comparison of observed (solid line) and predicted (broken line)
                 SFg isopleths; at each receptor point observed and predicted
                 (parenthses) SF, concentrations are also given in wg/m  .
                                        -217-

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                     TABLE 2.  Comparison of measured and calibrated meteorological data.
Run No.
1
9
10
11
15
Mean Wind Speed
(m/sec)
1.6
2.5
2.0
2.2
1.6
Mean Wind Direction
(deg)
Measured
340
335
330
340
330
Calibrated
360
355
350
355
355
ay(m/sec)
Measured*
0.07
0.02
0.01
0.01
0.09
Calibrated
4.4
2.5
1.8
2.5
2.5
A
Measured**
0.35
0.11
0.06
0.07
0.46
Calibrated
10.0
3.5
3.0
5.5
5.0
I
IS}
M
00
       *  assuming a  = a


      ** calculated as follows:
                      w
        where aQ in radian

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5.    HYDROCARBON EMISSION ESTIMATION AND DISCUSION5

     One of the initial tasks in determining the  method  for  predicting
hydrocarbon emission rates was  to  define  the sources.   The oil  refinery
chosen for this study has many fugitive hydrocarbon emission sources.  Each
source is characterized by the particular process associated with it.

     After the emission source is defined, the next step was to  determine
the most practical  and accurate way of modeling  them.  The AVQUAL
model, discussed in  Section 3, was then utilized to  calculate the relative
inrmacts of the different source types. Finally, a numerical technique was
devised to give a best fit emission rate in accordance with the  data.  The
method is as follows:

1.   For the emission source definition,  it was  decided to classify the
     numerous sources into areas of similar source types. Five source types
     were chosen for their dis+inct emission charateristics, namely, process
     areas  and  emulsion  plant (Q,), asphalt plant  (Q2),  loading-unloading
      facilities (Q3), fixed roof storage tanks (Q4), and floating roof storage
      tanks  (Q5).  Because not all of  the sources of any of the five types
     occurred together in a centralized area, smaller  areas  were defined
      which  contained  only  a particular  category.   The  final  scheme
      consisted of 31 defined areas:  five areas of Qi type, two areas of Qa
      type, two areas of Q3 type, fourteen areas of Q4 type, and  eight areas
      of Q 5 type. A diagram of the defined areas and their source category
      is depicted in Figure 3.

 2.    The defined area is further  subdivided into a number of point sources
      whose optimum spacing was determined.  It was found that  by reducing
      the  spacing   of  point  sources  the  error  of estimating downwind
      concentrations from an area source was reduced. However, it was also
      found that further reduction  from   a spacing of 25 feet would not
      result in a significant improvement in the model output.  For example,
      reducing the  spacing  from 25 feet to  12.5 feet  would increase the
      accuracy by less  than 2%.  Thus, a spacing of 25 feet  was  used in the
      emission prediction.   Within the unit area of 25  feet square,  it was
      assumed that the source points were distributed evenly.  This approach
      allowed for equal emphasis of  the different  source categories on an
      area basis.

 3.   The AVQUAL model can be expressed in a simplified form as follows:
                          = f (meteorology, coordinates)
       Thus,  X/Q can be calculated solely from the meteorological data and
       the coordinates.  For a unit area k of emission type j, its contribution
       to the ambient concentration at receptor point i (Xlt k  ) is identical
       to Qjf ijk  .  Thus, the total  contribution of refinery emissions  to
       receptor i can be expressed as
                                -219-

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O
                                                                                             Ql: Process Areas, Emulsion Plant 0-5)
                                                                                             Q2: Asphalt Plant (6-7)
                                                                                             Q3: Loading-Unloading Facilities (8-9)
                                                                                                 Fixed Roof Storage Tanks (10-23)
                                                                                             Q5: Floating Roof Storage Tanks <2*-31
                                                   m    mm
                                               '    €l»«^^
                     AIRLAB
                        RELEASE
                        DOUGLAS  OIL COMPANY
                        Paramount, California
              FIGURE 3.    Source definitions used for the refinery emission prediction.

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                                  5  k
                           X   = I  I
                                        j ijk

                                 =l k=l
     In Equation (2),   Jj was measured and f j j k was calculated from the
     calibrated  meteorological data; with  Qj 's the  only  unknowns  to  be
     solved.  Therefore, theoretically,  only five  downwind receptor points
     were needed to solve the equation since only five  source  types  were
     assumed.

4.    Realistically, however, more  receptor  points  were needed for the
     accurate prediction.  In this study as many as  15 downwind receptors
     were used.  A numerical analysis technique was therefore necessary to
     solve the over-determined set of equations.

5.    A linear programming approach with a non-negative  Q constraint was
     used  for solving the over-determined case.  This technique, however,
     was very sensitive to the variation of receptor concentrations; a noise
     of  + 5%  in receptor concentrations  was about  its  tolerable  limit.
     Eventually it was necessary to smooth out the receptor concentration
     data by fitting the receptor  points with the same downwind distance to
     a 2nd-order polynomial equation.  The hydrocarbon  emission prediction
     thus obtained gave  the most consistent results.

6.   The hydrocarbon concentration correlation factor  obtained in Section
     4.1 was applied to the predicted emission rates.

     Table 3 presents  the  results of the emission rate predictions.  Emission
rates from five different  source categories as well as the total  rate are
tabulated  for each  run.  Run   1 indicates the  Q5  source type  was the
predominant  source, while the  rest  of  the emissions came from the  Qi
category; Q2, Q3 and Q4 were negligible sources.  Run 9, however, shows
that Q,  and  Q5  types  were  approximately equally weighted as far as
contribution  to  the total emission  rate,  whereas the contribution from
source types Q2, Q3  and Q4 were still negligible.  Runs  10, 11, and 15
predicted that the emissions were predominantly from the Q, type.

     One  would not expect to observe  a change in the  predominant  source
type from hour to hour, such as the case  observed  for Runs 9, 10 and 11
which  were conducted on November 30.  Also, one would  not expect  the
change from day to day because of the fairly steady refinery operations.
Therefore, the average of  the five runs should be more significant  as far as
interpretation.  As shown in Table 3, the arithmetic average of the  source
type emissions indicates that Q,  contributed  about  60% of total emissions,
while Q5 contributed about 40%; Qa, Q3 and Q4 were essentially negligible.
The average total emission rate  from the Douglas refinery was  predicted to
be 26 Ib/hr.
                              -221-

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TABLE 3.
Hydrocarbon emission predictions for various source
categories of the refinery in Ib/hr.
Run No.
1
9
10
11
15
Avg.
Q!
8
14
12
18
23
15
Q2
0
0
0
0
0
0
Q3
0
0
0
0
0
0
Q*
0
0
3
1
0
1
Q5
39
10
0
0
0
10
Total
47
24
15
19
23
26
              =   process areas and emulsion plant

              =   asphalt plant

              =   loading-unloading facilities

              =   fixed roof storage tanks

              =   floating roof storage tanks
                                 -222-

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     This predicted value is about one order of magnitude lower than that
in the KVB source testing results, presented in Table k (KVB, 1977).  Also
presented is the  KVB estimation  of  the  Douglas  refinery hydrocarbon
emissions by using the  Southern California APCD and AP-42 emission data.
The  KVB source testing was  conducted at the same time periods as the
ambient testing was performed to formulate a coherent testing program.

     Compared  to these values, AV's prediction  appears to be  too  low
quantitatively.   Qualitatively, however, it is sensible.  A  major  part of the
emissions came  from the process areas and the floating roof storage tanks,
The  asphalt plant  contributed  little, if any,  to the  total emissions.   Fixed
roof  storage  tanks   normally  should contribute  to the  source  term.
Nevertheless, the  ambient  testing was conducted during the early morning
hours when the fixed  roof storage tanks were "breathing in."  Thus, the
prediction  of  negligible emissions  from this  particular source  type  is
reasonable.

      Possible  causes of the discrepancy between the AV prediction and the
KVB source testing results include hydrocarbon layering under the extremely
stable atmospheric conditions, and heavier hydrocarbon  retainment within
the  refinery because  of the  boundary wall.   Source testing data clearly
indicated CH4  emissions from  the refinery  (KVB, 1977). However,  AV's
ambient testing data  showed little or no difference for the  upwind and
downwind CH4  data.  It is possible that under the very stable conditions
most of the CH4 emitted would diffuse upward, and thus was not detectable
in the ground level.   Heavier hydrocarbons (in reference to air) under the
same stable atmospheric conditions would tend to  diffuse downward.  They
were, however, more  or less  contained in the refinery by the existence  of
the  wall in the downwind  side of the  refinery.  The results of the above
possible causes would be the  reduction in  the  ambient air  hydrocarbon
concentrations; and thus, the underestimation  of emissions.
                                  -223-

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TABLE 4.       Comparison of KVB's preliminary hydrocarbon emissions source
                testing results with the results calculated by using the SCAPCD
                and AP-42 data for the refinery; in Ib/hr.


Stack Emissions
Fugitive Emissions
Tank Storage and Transfer
TOTAL

SC APCD
11
8*
90
185
AP-42
26
123
95
244
KVB/ARB
24-Hr.
13
54
95
162
Av. Night
13
54
67
134
                                -224-

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6.   CONCLUSIONS AND RECOMMENDATIONS

     The following conclusions  may  be drawn as a  result of the ambient
testing of the refinery:

1.   The AVQUAL model can be adequately applied to the Douglas refinery
     environs.

2.   Emission prediction results for  various source types are qualitatively
     sound.   The  predominant  sources  during  the  test hours  were  the
     process areas and the emulsion plant (source type Q,) and the floating
     roof storage tanks (source types Q5).

3.   Quantitatively, the prediction is one order of magnitude lower  than
     predictions by accepted emissions factors or from source testing.  This
     is  possibly caused by the hydrocarbon layering  in  the immediate
     atmosphere, and  also by  the  existence of  a  wall  at the refinery
     boundary in the downwind side.

     For future hydrocarbon source  emission predictions using the ambient
testing approach, the following are recommended:

1.    Meteorological parameters should  be measured  at a site which  is
      representative of the source area.  The possible heat output from the
      area should be taken into consideration in the site selection.

2.    Receptor  locations should be set up close to the source area in order
      to  observe maximum impact.

3.    Instead  of extremely  stable atmospheric  conditions  (Class F), the
      testing can be done  under  less  severe conditions,  such as Class D,  to
      provide  better air  mixing.   Alternatively, if the study  has  to be
      performed under  Class F conditions, the collection of air samples  at
      three different  heights  would  be desirable  to detect  any  layering
      problem.

k.    More receptors  should be  arrayed  crosswind for  the same downwind
      distance to facilitate the data smoothing technique.

 5.    Avoid  selection  of source  area  with  wall perimeters  so  that  no
      boundary  type problem will exist.  In so  doing,  the  source-receptor
      relationship would be solely governed by atmospheric diffusion.

      In   summary, hydrocarbon  emission prediction   through  diffusion
 modeling  represents  a unique  approach  to the  inventory problem.   No
 statistical analysis is  needed,  as is with the case of direct source testing.
 Also,  theoretically, every hydrocarbon  source  is accounted for since the
 mixed refinery  plume  is collected at  the downwind locations.
                                -225-

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     The  apparent weakness  of  this approach  lies on the fact that the
measurement system might provide too  much of an error for the model to
handle.  A variation of  + 5% for the downwind concentrations proved to be
intolerable.   Eventually, it was necessary  to  smooth out the data to cut
down the noise.

     One way to improve the sampling accuracy would be  to arrange the
receptor locations closer to the source so  that maximum  impact  can be
observed,  and thus the  percent error of the receptor point  concentrations
can be minimized. Another way would  be  to  utilize real  time,  continuous
hydrocarbon monitors for all receptor points.  This  way the  handling of air
samples is cut down  to  minimum,  and thus the  most accurate results are
achieved.  However, this approach is expensive.  The methods employed in
this study, i.e., on-site analyses of integrated  samples, should be the most
economical and acceptable procedures.
                             -226-

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7.    REFERENCES

AeroVironment (1977): Ambient monitoring and source receptor identifica-
     tion of hydrocarbon emissions from oil refinery, AV FR 700^.

KVB (1977):  Control of hydrocarbon emissions from  stationary sources in
     the California South Coast Air Basin, KVB 5804-714.

Lissaman, P.B.S. (1973):  A simple unsteady concentration model explicitly
     incorporating ground roughness and heat flux.  Paper presented at  the
     66th annual meeting of the Air Pollution Control Association, Chicago,
     Illinois.  (AV TP 311,  AeroVironment Inc., Pasadena, Ca.)

Pasquill, F. (1962): Atmospheric diffusion . D. Van Nostrand, New York.

Taylor, G.I. (1921):   Diffusion by  continuous  movements.   Proc.  London
     Mathematical Society 20, 196-212.
                               -227-

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MEASUREMENT OF FUGITIVE EMISSIONS FROM PETROCHEMICAL PLANTS

                             by

                       D. R. Tierney
                        Z. S. Khan
                       T. W. Hughes
               MONSANTO RESEARCH CORPORATION
                     DAYTON LABORATORY
                   Station B, P.O. Box 8
                    DAYTON, OHIO  45407
                            -229-

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                                   ABSTRACT

Fugitive hydrocarbon emissions from petrochemical plants were measured as
part of an emission assessment program being conducted by Monsanto Research
Corporation under contract with the U.S. Environmental Protection Agency  (EPA).
The objective of this study was to provide accurate data on fugitive emissions
which would reflect current technology and operating practices in the petro-
chemical industry.  Field sampling and analysis was conducted at four plants
producing monochlorobenzene, butadiene, ethylene oxide/glycol, or dimethyl
terephthalate.

Fugitive sources at petrochemical plants include pumps, valves, flanges,
process drains, compressors, agitators, sample valves and relief devices.  A
random sample of potential sources at each plant was selected and screened
with an organic vapor analyzer to determine sources having hydrocarbon emission
rates in excess of 0.5 g/hr.  These sources were enclosed in a flexible plastic
tent and sampled using a portable sampling train.  On-site hydrocarbon sample
analysis was performed using a gas chromatograph with flame ionization detec-
tion to identify and quantify each organic component.  Sampling data showed
the average hydrocarbon emission rates from pumps, valves, flanges, and com-
pressors to be 22 g/hr, 4.5 g/hr, 1.4 g/hr and 30 g/hr, respectively.  Of the
total number screened, the estimated percentages of pumps, valves, and flanges
having significant (>0.5 g/hr) emission rates were 23%, 7%, and 2%, respec-
tively.  The number of such sources at petrochemical plants having signifi-
cant emissions is ^20% lower than the number of such sources at petroleum
refineries.
                                      -230-

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                                 INTRODUCTION

BACKGROUND

Hydrocarbon emissions from petrochemical plants can be divided into two broad
categories:  stack and fugitive emissions.  Stacks and/or vents identified as
principal hydrocarbon emission points are considered to be controlled sources.
Hydrocarbon emission points other than stacks and/or vents are considered to
be fugitive sources.  Fugitive emissions may occur due to accidents, inadequate
maintenance, or poor planning, although many fugitive emissions occur even in
the absence of such conditions and are unavoidable characteristics of some
process operations.

The emission factors generally employed for fugitive hydrocarbon emissions are
based on a study conducted to determine miscellaneous hydrocarbon emissions
from petroleum refineries in the late 1950's by Los Angeles County  (Ref. 1).
These emission factors are being used by both industry and air pollution
agencies to estimate emissions from fugitive sources, with little or no modi-
fication to reflect current equipment, technology, and operating practices.
Current data on the amount and composition of fugitive hydrocarbon emissions
from petrochemical plants  also are not available; they are at best estimated.
Therefore, sampling efforts were necessary to obtain data of the required
quality and accuracy and to identify and quantify emissions of potentially
toxic chemical substances.

The EPA is currently conducting a study on fugitive hydrocarbon emissions from
petroleum refineries to determine the adequacy of established emission  factors
in light of current refinery technology and equipment.   Information on  fugitive
emissions from petrochemical plants generated in this study will be used by the
EPA to compare fugitive emissions from such plants with  those from petroleum
refineries.

SCOPE OF STUDY

Fugitive hydrocarbon emissions were measured at plants manufacturing mono-
chlorobenzene, butadiene, ethylene oxide/glycol, and dimethyl terephthalate.
Hydrocarbon emission rates were determined for pumps, valves, flanges,  process
drains, compressors, agitators, sample valves, and relief devices.  On-site
analysis was performed to identify individual organic components.   Sampling
results were extrapolated to evaluate fugitive emissions from all potential
point sources within each process.

Data on fugitive emissions from petrochemical plants and petroleum  refineries
were compared.  Petroleum refinery data were acquired from the study conducted
by Los Angeles County  (Ref. 1).
                                      -231-

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                              SAMPLING AND ANALYSIS
SOURCE SELECTION

Potential fugitive  sources  at  a petrochemical plant are numerous and varied.
Due to budget and time constraints  it was not feasible to determine whether
each source type was emitting  fugitive hydrocarbons.  In order to define the
number of sources required  to  achieve statistically relevant data three factors
were required.  Two of the  factors  are the desired confidence level and the
corresponding error.  On this  program ,  these factors were established as the
95% confidence level and a  corresponding error of ± 70%.  A third  factor
needed to define the number of samples required is the standard deviation of
the measurements.  Assuming that sampling data follow a normal distribution
with no bias, the following relationship exists:
                                    S   =
                                    x
                                         Ii/n
where:
           = estimated  relative standard deviation
         X,
         E = error  (difference  between true emissions and
             mean of measurements,  ±70% for this program)

         n = number of  samples

         t = value from statistical tables for "t" distribution

A plot of sx versus n is given  in Figure 1 which was used to predict the mini-
mum number of sources required  from estimated relative standard deviations to
obtain ±70% uncertainty.
                            20   40  60 80 100   200   100
                             ESTIMATED RELATIVE STANDARD DEVIATION. %
         Figure 1.  Number of samples required  for fugitive sampling.
                                     -232-

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Fugitive source types which were found at the various petrochemical plants
included pumps, valves, flanges, compressors, relief valves, sample valves,
process drains, and agitators.  Each plant site was inspected prior to sampling
to determine the existence of any unusual process configurations.  Unusual con-
figurations, such as open vessels containing hydrocarbons, were not found at
the plants sampled.

To guarantee that a sufficient number of samples was obtained, approximately
40 samples of each source type were tested whenever possible.  Sources were
selected randomly throughout each plant to insure that fugitive emissions
sampled were representative of and resulted from the process being studied.

Source selection was randomized by one of two methods.  The preferred method
was to utilize process instrumentation diagrams which depict all pumps, valves,
compressors, etc.  The depicted sources were sequentially numbered on the
diagram, and a random number table was used to determine which numbered sources
were to be tested.

Many process instrumentation diagrams were, however, either not  sufficiently
detailed or were outdated, rendering the above method impractical.  In this
instance potential fugitive sources were selected by placing a plastic grid
over a diagram of  each unit operation or process.   Based on the  size and  shape
of the available diagram, each  square millimeter covering the area was consec-
utively numbered.  A random number table was then used to select corresponding
squares on  the grid.   These points were then transferred to the  diagram.  The
diagram, marked with the number of screening sites  selected, was taken into
the field for  source selection.  Fugitive sources located nearest  to the  area
marked on the  diagram  were then tagged for  source screening.  Figure  2 shows
the selection  of sampling  sites in a  storage tank area.
      501
     1,001
     1,501
     2,001
     2,501
     3,001
     3,501
(TO
                           NOTES
                           GRIDS ARE NUMBERED SEQUENTIALLY
                           FROM LEFT TO RIGHT, TOP TO
                           BOTTOM.

                               INDICATES LOCATION OF GRID
                           ® CORRESPONDING TO RANDOM
                               NUMBER
                               INDICATES STORAGE TANK
                               LOCATION IN PLANT
             710
                  1,430   2,130   2,WO   3,550
            Figure 2.  Selection of screening sites in plant storage
                       tank area using random numbers.
                                       -233-

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The selection of sources for screening was supervised by the plant's  engineer,
who was responsible for ensuring that all selected sources were a part of the
manufacturing operation being tested.

FUGITIVE SOURCE SCREENING

Fugitive emissions were detected using an Organic Vapor Analyzer  (OVA),
Model 128, obtained from Century Systems Corporation.  The OVA-128 instrument
utilizes a hydrogen flame ionization detector  (FID) sensitive to 1 ppm of
organic vapor and provides a direct meter readout with a 2-second response
time.  The instrument is available with a linear readout covering three ranges:
0 to 10 ppm, 0 to 100 ppm, and 0 to 1,000 ppm.  Using a calibrated dilution
probe, the instrument's readout capabilities were increased to include ranges
of 0 to 10,000 ppm and 0 to 100,000 ppm.

In prior studies, the EPA has determined that  for a fugitive source an OVA
instrument reading of greater than 200 ppm corresponded to an approximate emis-
sion rate greater than or equal to 0.5 g/hr.   For this study, it was  estab-
lished that only sources with emission rates greater than or equal to 0.5 g/hr
would be sampled.  Therefore, if a hydrocarbon concentration greater  than
200 ppm was detected by the instrument at any  fugitive source, that source was
prepared for sampling.

Pumps, Compressors, Agitators, and Valves

The OVA-128 instrument was used for screening  pumps, compressors, agitators,
and valves by placing the instrument probe as  close as possible to the inter-
section of the shaft and packing gland at four points, 90° apart.  If a
hydrocarbon concentration in excess of 200 ppm was detected at any point, the
source was prepared for sampling.

Flanges

Fugitive emissions from flanges were screened  using one of two techniques
depending upon the condition and accessibility of the flange.

The first method, used for screening large, relatively cool vessel and exchanger
flanges, involved taping the outside perimeter of the flange interface, thus
effectively sealing the interface.  A small hole was then punctured into the
tape seal.  Hydrocarbons leaking from any point around the flange were emitted
through the puncture, and they were screened in a manner similar to that dis-
cussed for screening of valves.

The second method, applicable for smaller and/or hot flanges, involved placing
the OVA-128 instrument at 50-mm intervals all  around and against the  outside
perimeter of the flange interface.  All instrument readings of 10 ppm or
greater were recorded.  If the sum of all the  readings taken around the perim-
eter exceeded 200 ppm, the flange was prepared for sampling.

Relief Devices, Process Drains, Sample Valves

Relief valve emissions were vented to the atmosphere through a large  diameter
pipe, normally located at a high point on the  unit which it served.   Relief
valves were screened by inserting the OVA-128  instrument probe into the stack


                                      -234-

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and measuring the hydrocarbon concentration at this point.  The ambient concen-
tration was also determined.  If the difference between the stack and ambient
concentration exceeded 200 ppm, the relief valve was prepared for sampling.

Fugitive emissions from process drains occurred at points where the drains are
vented to the atmosphere.  Emissions are vented through a perforated steel
plate built into the ground directly above the drain.  .Process drains were
screened by placing the OVA-128 instrument probe near the steel plate outlet.
If the instrument detected a hydrocarbon conentration greater than 200 ppm,
the process drain was prepared for sampling.

Process stream samples are collected from sample valves at regular intervals
by plant personnel during normal operation at a petrochemical plant.  Sample
valves were screened for fugitive emissions by placing the OVA-128 instrument
probe near the open spout of the sample valve.  If a total hydrocarbon concen-
tration greater than 200 ppm was measured, the sample valve was identified for
sampling.

SAMPLING OF FUGITIVE VAPORS

Field sampling of fugitive organic vapors was accomplished using  the dilution
or flow-through method.  Two separate  sampling trains, the vacuum sampling
system and the pressurized sampling system  (shown in Figures  3 and 5), were
used.  The trains were mounted on a portable cart for easy maneuverability
from source to source.

Vacuum Sampling System

This sampling train, shown in Figure  3, was equipped with a pneumatic  vacuum
pump, an orifice meter and a sampling  syringe.  A cold trap was placed in the
system to condense water and heavier hydrocarbons and to  prevent  condensation
in downstream lines and equipment.  The fugitive emission source  identified
through screening was prepared for sampling by tenting.   In the tenting  proce-
dure, the leaking source  (e.g., a valve) was enclosed in  a flexible  Mylar®
tent as shown in Figure 4.  Ambient air was drawn across  the  emission  source
for approximately 20 minutes before sample collection in  order to achieve
equilibrium conditions inside the tent.  Steady-state conditions  were  deter-
mined by using the OVA-128  instrument  to measure exit gas concentration.

Samples were obtained by drawing a portion of the gas from the main  flow using
a  500-ml glass syringe and  then  injecting the gas sample  into an  evacuated
Teflon® bag.  The vacuum pump was capable of maintaining  a flow rate approxi-
mately 0.037 m3/min to 0.034 m3/min during  sampling.  The source  emission rate
was determined from the  air  flow rate and the hydrocarbon content of the
collected sample.  Ambient  air  samples were obtained in  the vicinity of  the
leaking source prior to  sampling and  analyzed  for hydrocarbon content to deter-
mine background  concentrations.  If the background  hydrocarbon  concentration
was high  (>10 ppm) or  if the  source being sampled was  in close  proximity to
another fugitive  source  the pressurized  sampling train was used as  described
below rather than the  vacuum  system.
                                      -235-

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                              THIS LINE SHOULD BE
                             AS SHORT AS POSSIBLE
                                    ORIFICE
                                     METER
                   TENT
on   >
                        v_^
                  LEAKING VALVE
rCOLD TRAP
  (ICE BATH)

   THREE WAY
    VALVE
                                            SAMPLE
                                             BAG
                                                                       EXITGAS
                                                               VACUUM PUMP
                                        SYRINGE
              Figure  3.   Portable sampling train,  using  a vacuum pump
                          for  sampling  or fugitive hydrocarbon  emissions.
                       SUHfR DUCT TAPE
                         SAG SEAL
                     MYIAR BAGGING
                     FLEXIBLE PLASTIC
                     MESH REINFORCING —	  \
                    MATERIAL BENEATH BAG
     Figure  4.   Tent  construction around the  seal area  of a vertical valve.
        DESICCANT
        COLUMN
                          ORIFICE
            CONTROL     / MEFER
PLANT
 AIR
                                 VALVE
                               C*3=
            CHARCOAL
             COLUMN
                                                                                EXITGAS
                                                   THREE WAY
                                                     VALVE
                                               LEAKING VALVE

        Figure  5.   Portable sampling train, using plant  air for  dilution
                    and  sampling  of fugitive hydrocarbon  emissions.
                                          -236-

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Pressurized Sampling System

The pressurized sampling train shown in Figure 5 employed plant air for dilu-
tion and sampling.  Plant air under pressure was first passed through a
charcoal filter and desiccant to remove hydrocarbons and moisture, and then
directed through the train and into the tent.  After steady-state conditions
were established, a sample bag was connected to the tent and filled by means
of the incoming dilution air.

The vacuum system was the preferred sampling method because filling the sample
bag was not dependent upon air flow through the tent.  This permitted less
complicated tenting procedures to be used and resulted in a substantial savings
in sampling time.  Also, the vacuum system was equipped with a cold trap to
condense heavy hydrocarbons.  If heavy hydrocarbons were to condense inside
the sample bag of the pressurized system prior to GC analysis, a  significant
error could be introduced into the data.

The pressurized sampling system was used to sample sources located in areas
where high ambient hydrocarbon concentrations existed or when fugitive  sources
were close to each other.  In these cases it was felt that the magnitude of
and variations in the background concentration would introduce errors into the
emission rate calculations for the vacuum system.  Dilution air in the  pres-
surized sampling system was essentially free of hydrocarbons and  water  since
it was passed through a desiccant and activated carbon prior to mixing  with
hydrocarbons from the tented source.

SAMPLING OF LIQUID LEAKS

Liquid leaks were defined as those leaks  from which  liquid was observed to
escape.  If the  liquid vaporized rapidly  and completely  in the vicinity of the
escape point, the emission was treated as a vapor  leak and tented.

In order to measure  the liquid leak  rate  at the  source,  the material  was
collected  in a graduated container,  which was externally cooled with  ice and
fitted with covers to contain most of the material.   Flow rates were  determined
at the leak site by  measuring the change  in volume with  respect  to time.

ANALYTICAL PROCEDURES

Analysis for  individual Organic  Species

After  completion of  a  sampling run,  the  sample  bags were transported to the
field  analytical laboratory.  Analysis of bag  contents  was carried out using
either a Hewlett Packard  Model  5750  or  a Varian 1400 gas chromatograph,
equipped with flame  ionization detectors.  The  gas chromatograph was interfaced
with a Varian GDS-111  microprocessor to  convert the chromatograph detector out-
put  into a digital  integrated output.   The system allowed storage of standard
sample data;  it  provided  data output for each sample in the form of retention
times  and  peak areas;  and it identified  and quantified each component found
in the samples.
                                       -237-

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Analysis for Total  Hydrocarbons

If unknown hydrocarbon components were found during  sample  analysis, the sample
was rerun and the total hydrocarbon content was measured.   Total hydrocarbons
were analyzed in the  field by bypassing the GC column  and  injecting the gas
sample directly into  the flame ionization chamber.

Laboratory Analytical Procedures

All gaseous samples collected were analyzed in the field.   Selected sample bags
were returned to the  laboratory for GC/MS analysis.  This was done to verify
field measurements  and to identify any unknown components.

Liquid samples collected in the field comprised liquid leaks  and condensate
collected in the cold trap.  These samples were returned to the laboratory for
identification and  quantification of each organic component present by gas
chromatography/mass spectroscopy.

                                     RESULTS

Petrochemical plants  manufacturing monochlorobenzene,  butadiene, dimethyl
terephthalate, or ethylene oxide/glycol were selected  for  fugitive emission
sampling since they are representative of a variety of operating conditions
and unit operations.   Characteristics of each process  are  described in Table 1.

               TABLE  1.   CHARACTERIZATION OF CHEMICAL  PROCESSES
                          SAMPLED IN FUGITIVE EMISSION  PROGRAM


                                               Process
                            Monochloro-              Dimethyl-      Ethylene
        Characterization	benzene    Butadiene  terephthalate  oxide/glycol

    Operating
     temperature/pressure
     range                     low/low    high/high    high/low      low/high

    Unit Operations Utilized

      Distillation                x          x           x            x
      Absorption                             x
      Scrubbing/washing            x                      x
      Extraction                             x
      Evaporation                            x                        x
      Crystallization                                     x            x
      Drying                                             x            x
      Quenching                              x
      Storage                     x          x           x            x

    Unit Processes Utilized

      Oxidation                                          x
      Hydrogenation                                      x
      Pyrolysis                              x
      Esterification                                     x
      Hydration                                                       x
      Chlorination                x
                                       -238-

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Average hydrocarbon emission rates are given in Table 2 for source types in
each process.  These emission rates are based on sources that were found to
have hydrocarbon concentrations in excess of 200 ppm as determined by screen-
ing.  The estimated fugitive emission rate for all potential sources is also
given; it is based on the mass of fugitive emissions divided by the total
number of sources.  An analysis of variance was performed to determine the
effect of operating temperatures, pressures and fugitive compound vapor pres-
sures on the variability in emission rates from each pump, valve and flange
sampled.  Results of this analysis indicated that the factors tested had no
significance in relation to the corresponding emission rates from each sampled
source.

Table 3 gives the estimated annual mass of fugitive emissions from each
process.  This information was derived from the number of potential fugitive
sources at each plant and the estimated average emission rates for all poten-
tial sources, as shown in Table 2.

In butadiene production valves were the most significant fugitive source, con-
tributing 90% by weight of the total fugitive emission burden from the plant.
In monochlorobenzene production flanges contributed 91% of the total fugitive
emissions and thus were considered the most significant source of fugitive
losses at the plant.  For ethylene oxide/glycol and dimethylterephthalate pro-
duction data on the total number of valves and flanges were not available, and
consequently no emission mass estimates were made.

Factors which determined the magnitude of fugitive emissions from various
source types  (i.e., pumps, valves, flanges, etc.) included 1) total number of
potential sources in each process, 2) average emission rate for significant
fugitive sources, and 3) percentage of sources having significant emission
rates.9  The total number of each source type was found to have the most impact
on the overall fugitive emission burden for a petrochemical plant.  This was
due to the high variability in the total number of potential sources for dif-
ferent source types.  For example, in the butadiene production plant sampled
there were 174 pumps and 6,700 valves.  Variations in the average emission
rates and in the percentage of sources having significant emissions for these
two source types were small compared to the differences in number of sources.
Thus the total emissions contributed by valves is very much larger than the
total fugitive emissions from pumps.  Since the total number of valves and/or
flanges was large compared to the number of other source types  (pumps, com-
pressors, etc.),at each plant sampled, valves and/or flanges are considered
the major sources of fugitive emissions from petrochemical processes.

Fugitive emissions were identified and quantified in the field by gas chromato-
graphic analysis.  Table 4 lists the organic compounds detected along with
their weight percent contribution to the total mass of fugitive emissions
determined for each process.  On-site analysis was verified by  laboratory mass
spectroscopy; it was determined  that greater than 98% by weight of  the  fugi-
tive emissions sampled were identified.  Potential human health effects  from
exposure to various compounds detected are described in footnotes in Table  4.
 Significant  fugitive  sources are those having a hydrocarbon emission rate
 greater  than or  equal to 0.5 g/hr.


                                      -239-

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                       TABLE 2.   HYDROCARBON EMISSION RATES FOR FUGITIVE SOURCES  BY PROCESS
                                                         Ib/hr  (g/hr)
Source type
Pump seals
Average emission
Monochlorobenzene
5.1 x HP2
(23)
Compressor seals

Valves

^ Flanges
O
Relief devices

Process drains

Agitator seals
Sample valves
Note . — Blanks

3.4 x 10-3
(1.5)
1.8 x 10"1
(82)



4.4 x 10"1
(200)

rate for significant fugitive sources
Butadiene
3.7 x KT1
(160)
1.3 x 10-1
(59)
2.5 x 10-1
(120)
0
(0)
3.0 x 10~2
(14)




indicate source type nonexistent
Dimethyl-
terephthalate
4.5 x 10-2
(20)


7.0 x 10~2
(32)
2.4 x 10-1
(110)
0
(0)


4.8 x lO"1
(218)
2.0 x lO"1
(91)
in process.
Ethylene
oxide/glycol
1.8 x 10-1
(82)
2.5 x 10-2
(11)
3.5 x 10-3
(1.6)
2.0 x 10-3
(1.0)
0
(0)
1.5 x 10-1
(68)



Average emission rate for
Monochlorobenzene Butadiene
1.7 x 10~2 1.4 x KT1
(7.7) (63)
1.2 x 10-1
(54)
1.0 x 10-1* 3.7 x 10~2
(0.05) (17)
4.9 x 10~3 0
(2.2) (0)
1.4 x 10~2
(5.0)


4.4 x 10"1
(200)


all potential
Dimethyl-
terephthalate
7.4 x 10~3
(3.3)


3.3 x 10~3
(1.5)
7.6 x 10~3
(3.4)
0
(0)


3.2 x 10-1
(145)
8.6 x 10~2
(40)

b
sources
Ethylene
oxide/glycol
2.9 x 10~2
(13)
1.3 x 10-2
(5.9)
1.6 x 10-"
(0.07)
6.7 x KT5
(0.03)
0
(0)
8.9 x 10"2
(40)



Significant fugitive sources are those having an emission rate greater than or equal to 0.5 g/hr as determined by sampling and analysis.
Emission rates were determined by calculating the mass of fugitive emissions  from the emission  rates for significant sources.  The mass
of emission was divided by the total number of sources screened to arrive at  an average fugitive emission rate for all sources.

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      TABLE 3.   MASS OF FUGITIVE EMISSIONS FROM PETROCHEMICAL PROCESSES
  Process source
   Number of
sources present
              a
Estimated mass
 of emissions,
 metric tons/yr
   Total mass of
fugitive emissions,
  metric tons/yr
Monochlorobenzene
Pumps
Valves
Flanges
Other
Butadiene
Pumps
Valves
Flanges
Other

Ethylene oxide/glycol
Pumps
Valves
Flanges
Other

Dimethylterephthalate
Pumps
Valves
Flanges
Other

25
640
1,500
_b

174
6,700
26,000
218


69
_b
-b
26


67
_b
_b
37

1.0
0.2
29
1.7

96
1,000
0
16


8.0
_b
_b
7.9


2.0
_b
_b
8.6
31.9




1,112




b





b






Determined from average emission rate from all potential sources as shown in
Table 2.

Data not available.
                                     -241-

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              TABLE 4.  PERCENT COMPOSITION BY WEIGHT OF FUGITIVE
                        EMISSIONS FROM PETROCHEMICAL PLANTS


                     Monochloro-                  Dimethyl        Ethylene
                      benzene,     Butadiene,   Terephthalate,   Oxide/glycol,
	Compound	%	%	%	%	

Acetaldehyde                                                          11
Acroleina                                                             12
Benzene"3                 41
i-Butane                              0.5
?!-Butane                              1.0
1,3-Butadienea                       28
1-Butene                             11
2-Butene                              1.5
Dichlorobenzene3          0.1
Diisobutenea>c                       33
Ethane                                                                <0.1
Ethene                                                                2
Ethylene oxide&                                                       73
Furfural9                             4
Isobutene                            21
Methane                                                               2
Methanolc                                            65
Monochlorobenzenea       59
Xylene                                               35


 Human health effect - irritant
b
 Human health effect - suspected carcinogen
C
 Human health effect - narcotic

Table 5 provides a comparison of fugitive emission rates for petrochemical
plants and petroleum refineries.  Emission rates for petroleum refineries were
derived from emission factors obtained during the sampling of fugitive sources
by Los Angeles County (Ref. 1-4).  The percentage of sources having emission
rates in excess of 0.5 g/hr for both petrochemical plants and petroleum refin-
eries is given in Table 6.
For significant fugitive sources, average emission rates at the petrochemical
plants sampled were 3% to 90% lower than corresponding emission rates for
petroleum refineries.  Average emission rates for all potential sources were
also found to be lower at the petrochemical plants than the established emis-
sion rates for refineries.  Of the total number of sources sampled, the
percentages of significant sources were lower for monochlorobenzene,  dimethyl-
terephthalate, and ethylene oxide/glycol production when compared to  refin-
eries.  For butadiene production, however, the percent of sources having
significant emission rates is essentially the same as that for refineries.
                                     -242-

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             TABLE 5.   COMPARISON OF FUGITIVE EMISSION RATES FOR
                       PETROCHEMICAL PLANTS AND PETROLEUM REFINERIES
                          Ib/hr/source (g/hr/source)

a
Significant fugitive sources
Source type
Pump seals

Compressor seals


Valves

Flanges

Process drains

Relief valves

Petrochemical
Plants
1.6 x 10— '
(73)
7.7 x lO-2
(35)

8.2 x ID"2
(37)
1.0 x 10~1
(45)
1.5 x 10-1
(68)
3.1 x ID"2
(14.3)
Petroleum
Refineries
(Ref. 1-4)
4.8 x 10— '
(218)
6.5 x 10~1
(300)
h
8.5 x 10~2
(38)
1.1"
(500)
_C

4.0 x 10— '
(183)
All potential sources
Petrochemical
Plants
4.8 x 10~2
(22)
6.6 x lO"2
(30)

1.0 x ID"2
(4.5)
3.1 x 10~3
(1.4)
8.9 x ID"2
(40)
1.1 X ID"2
(5.1)
Petroleum
Refineries
(Ref. 1-4)
1.7 x 10~1
(78)
3.5 x 10~1
(161)
u
1.1 X ID"2"
(5)
1.1 X 10-2b
(5)
C

1.0 x 10-1
(45)

 Significant fugitive sources are those having an emission rate greater than or
 equal to 0.5 g/hr.

 Data shown arebased on an average emission rate of 0.27 Ib/day/source.  EPA
 currently uses a value of 0.15 Ib/day/source for valves and flanges; however,
 this excludes sources with large leaks.
C
 Data not available.

In Tables 5 and 6 petrochemical plant fugitive emissions are shown to be gen-
erally lower in both magnitude and in the number of significant sources when
compared to data on refineries.  Two factors which may affect the variations
in fugitive emissions are given below:

   • process size - the petrochemical processes sampled were smaller
     in size than refinery operations and contained a fewer number of
     potential fugitive sources.

   • product value - products from petrochemical plants have a higher
     value per unit than refinery products.  Thus potential losses are
     better controlled.
                                     -243-

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           TABLE 6.  COMPARISON OF SIGNIFICANT FUGITIVE SOURCES IN
                     PETROCHEMICAL PLANTS AND IN PETROLEUM REFINERIES
a,b
                     Percent of sources having significant emission rates	
                                                         Ethylene  Petroleum
                  Monochloro-               Dimethyl-     oxide/   Refineries
                   benzene     Butadiene  terephthalate   glycol   (Ref. 1-4)
Pump seals
Compressor seals
Valves
Flanges
Process drains
Relief valves
20

3
3


39
95
15
0

36
16

5
3

0
16
50
4.5
3
59
0
36
54
13
1
_C
23

a
 Significant fugitive emission sources are those having an emission rate
 greater than or equal to 0.5 g/hr.
 Blanks indicate source type does not exist in process.
'Data not available.
                                  CONCLUSION
This study has identified and quantified fugitive emissions from various petro-
chemical plant processes.  Fugitive emissions from petrochemical plants are
generally lower in quantity when compared to EPA data on fugitive emissions
from petroleum refineries.

Physical differences in operating conditions and process materials showed no
relationship on variations in emission rates from individual sources.

                                ACKNOWLEDGEMENT

This research was funded by the Industrial Environmental Research Laboratory
of the U.S. Environmental Protection Agency, Research Triangle Park, North
Carolina, under contract 68-02-1874.  The content of this paper does not
necessarily reflect the views or policies of the U.S. EPA.
                                      -244-

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                                 REFERENCES

1.  Emissions to the Atmosphere from Eight Miscellaneous sources in Oil
    Refineries.  Report No. 8 (PB 216 668), Joint District, Federal and State
    Project for the Evaluation of Refinery Emissions, Air Pollution Control
    District, County of Los Angeles, California, June 1958.  57 pp.

2.  Compilation of Air Pollutant Emission Factors.  Publication No. AP-42,
    U.S. Environmental Protection Agency, Research Triangle Park, North
    Carolina, March 1975.  pp. 9.1-1 to 9.1-8.

3.  Steigerwald, B. J.  Emissions of Hydrocarbons to the Atmosphere from Seals
    on Pumps and Compressors.  Report No. 6,  (PB 216 582), Joint District,
    Federal and State Project for the Evaluation of Refinery Emissions.  Air
    Pollution Control District, County of Los Angeles. California, April 1958.
    37 pp.

4.  Boland, R. F., T. E. Ctvrtnicek, J. L. Delaney, D. E. Earley, and Z. S.
    Khan.  Screening Study for Miscellaneous Sources of Hydrocarbon Emissions
    in Petroleum Refineries.  EPA-450/3-76-041, U.S. Environmental Protection
    Agency, Research Triangle Park, North Carolina, December 1976.  91 pp.
                                     -245-

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                  DEVELOPMENT OF COATINGS TO REDUCE FUGITIVE

                        EMISSIONS FROM COAL STOCKPILES*
                                      by
                           R.V. Kromrey, R. Naismith
                         R.S. Scheffee, R.S. Valentine
                         ATLANTIC RESEARCH CORPORATION
                             Alexandria, Virginia
*  This work was sponsored by the Department of Energy, Division of Environ-
mental Control Technology under Contract No. EP-78-C-02-4632.
                                      -247-

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                                   ABSTRACT
          The use of coatings to prevent dust emissions and leachates from coal
stockpiles was studied under sponsorship of the Department of Energy, Division
of Environmental Control Technology.  The coatings considered included composi-
tions formed of a filler such as pulverized coal and a binder consisting of a
combination of waxes and plastics.  Various latex emulsions, both with and
without fillers, were also evaluated.

          The purpose of coal coatings is to seal the surface of the stockpile.
This prevents water penetration into the coal.  By sealing the surface of the
pile, dust losses are prevented and leachate formation is minimized.  Air cir-
culation through the stockpile is also greatly reduced.  This yields the added
benefits of reduced oxidation of the coal and prevention of spontaneous igni-
tion.  Cold weather handling characteristics of the coal are also improved.

          Physical properties of the coatings were measured.  Included were
such characteristics as resistance to water penetration and degradation as a
result of thermal cycling.  Application techniques were also evaluated.  Both
hot-applied and cold-applied coatings were considered.

          Protective coatings appear to be an attractive means of prevention of
fugitive emissions from coal stockpiles.  The economic benefits from reduced
oxidation and improved handling more than off-set the cost of application.  Use
of coatings on unit trains or barges may also be attractive.
                                      -248-

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                                 INTRODUCTION
          Coal from mines is transported to its ultimate destination by rail,
truck, barge or pipeline.  Once it arrives at its consumption point or a pro-
cessing facility, it is moved over short distances by rubber-tired loaders,
conveyors or rail shuttle cars.  During the transportation process, the coal
is often exposed to the elements.  This leads to dust emissions and losses
through wind effects.  Moisture absorption and oxidation also can occur,
causing deterioration of the coal and loss in fuel value (ERDA, 1976).


          Once at the destination, the coal is either used or stored.  Most
users maintain stockpiles comprising a 90-day supply at their normal use rate.
.This is done primarily to provide a reserve in the event of  temporary loss of
supply.  This stockpile may stand for a year or more before  it is necessary to
use it.

          In the stockpile, the coal is subject to weathering and oxidation.
Heavy dust emissions from stockpiles are common.  Absorbed moisture from rain
or snow causes leachate formation and may decrease the fuel  value of the coal
by 1 to 8% depending upon initial moisture level and coal rank.  Wind and rain
erosion results in coal migration and exposes new coal surface to weather.
Moist coal can also freeze solid in cold weather making normal handling im-
possible.  Oxidation may reduce the heating value up to 5% over a one-year
storage period  (ERDA, 1976).  In addition, internal oxidation can lead to spon-
taneous combustion in low rank fuels (ERDA, 1975; Paulson et al., 1975).

          This work presented here addresses the use of protective  coatings for
coal to resolve the environmental problems associated with transport and stor-
age.  These coatings not only minimize fugitive emissions, but can  also be
shown to provide dollar savings substantially greater than the costs of appli-
cation.

                              TECHNICAL APPROACH

          The overall objective of this work was to demonstrate the  feasibility
of economical coal coating systems.  To accomplish this, the following factors
were considered:

               Identification of suitable materials for coal coatings

               Development of formulations which are capable of reducing
               the adverse environmental effects of weathering of coal stores

               Identification of acceptable application techniques

          •    Tests to determine coating properties and provide data  for
               economic analysis
               Economic analysis of coatings compared to unprotected  coal

               Cost/benefit analysis
                                      -249-

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          The first task was intended to provide information to guide the ex-
perimental development of coal coatings.  The factors considered are listed
below:

               Evaluation of candidate filler-binder materials

               Review of current coal protection techniques

               Application considerations

               User motivation
          Filler-Binder Materials Evaluation

          A list of materials was generated which could be considered as candi-
dates for inclusion in coal coating formulations.  The candidate materials were
screened to establish their characteristics with respect to:

               cost
               availability

          •    fuel value
               physical properties
               environmental pollution potental

The filler materials considered included coal, paper, sawdust, bagasse, rice
hulls, cottonseed hulls, and fly ash.   Binder materials considered fall into
two categories.  The first included the materials useful for the hot-melt type
of coating such as waxes and plastics.  The second type of binder material was
the various latex emulsions.  This type of material was considered for use in
filled latex coatings.

          Pulverized coal and fly ash emerged as the best filler candidates.
Both of these materials are available at coal user sites in sufficient quan-
tities.  They are both available at little or no cost, taking into account
the credit for fuel value of coal.  Neither of these materials would cause
additional environmental problems upon combustion, as both are normally present
in coal combustion systems.  The other filler material candidates were either
too costly, limited in availability or presented potential environmental
problems.

          The best binder materials identified were slack wax, polyethylene,
atactic polypropylene for the hot-melt composition, and polyvinyl acetate
copolymers for the filled latex formulations.

          Current Coal Protection Techniques

          The most common current means of protecting coal is to carefully
build and compact the stockpile, then monitor it for hot spots.  At this time,
it is estimated that less than 5% of the users of coal provide additional
protection in the form of coatings.  Coal is shipped by rail car in as-dumped
condition.  It is estimated that 5-10% of the shippers use latex crusting
compounds to prevent wind loss and dust emissions in transit.  A discussion
of these current protection methods is provided below.


                                      -250-

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          Stockpile Formation

          Large users of coal generally maintain a stockpile sufficient to
provide coal for 90 days in the event of a strike or other loss of supply.  A
typical user requires 4,000 tons per day.  Thus, a stockpile of 360,000 tons
would be required.

          Stockpiles must be properly constructed; otherwise, the risk of spon-
taneous combustion is high.  Coal stores have been known to ignite spontaneously
within six days after pile formation (Wilson, 1975).  A typical method for con-
structing a coal stockpile is given below:

          1.   The coal is dumped from the rail cars either by bottom hopper
               or car inversion.

          2.   The coal falls onto a conveyor and passes through a mill where
               it is ground to <2-inch size pieces.

          3.   The coal is transported to the stockpile areas either by
               conveyor or by rubber-tired vehicle.

          4.   A bulldozer spreads the coal and compacts it.  Typical piles
               are in the form of a truncated cone, 100-200  feet wide at  the
               base and 25-50 feet high.  The length of the  pile may be up
               to thousands of feet.
                                                    2
Coal as dumped has a bulk density of about 50 Ib/ft .  After compaction,  the
bulk density is about 65 Ib/ft   (Paulson, et al., 1975).

          The stockpiling technique varies with coal source  and rank.  Higher
rank coal may be formed into larger piles of greater height  and stored longer
than low rank coals (ERDA, 1975).  East coast coals may be  stored longer than
west coast coals as they are less reactive.  The  finer the coal, the more  reac-
tive it is as a result of greater surface area.

          Small coal stockpiles may be stored as  dumped for  short periods.
Such piles should not exceed 15  feet in height  (Wilson, 1975).  Longer term
storage of uncompacted coal is risky in terms of  spontaneous combustion danger.
Uncompacted coal piles should be used within a  few  days of dumping.

          Stockpile Protection

          Stockpiles are formed  solely by the action of a  bulldozer in shaping
and compacting the pile.  Thermal probes are sometimes buried  in the  coal to
monitor pile temperatures.  The  probes set off  an alarm if the pile temperature
reaches 130-140°F  (54-60°C).

          Dust emissions from coal stockpiles are a problem  of  increasing con-
cern.  Some users reduce dust formation by washing  the coal  before piling and
transporting it wet.  Other users wet the pile  after formation or spray  it with
oil to reduce dust emissions.

          Leachate formation is  also a serious  problem except  in the  case of
very high grade coal.  Water runoff  from the pile is collected in a trough
                                      -251-

-------
around the pile.  It is then sent to a holding tank or pond where it is treated
before discharge to the environment.  The treatment generally consists of in-
troducing a flocculant or precipitating agent, then allowing the solids to
settle out before discharge.

          Few users currently protect their stockpiles against oxidation and
the resultant fuel value losses.  ERDA (1976) reports that losses up to 5% may
occur in the first year of storage.  Leonard (1968) found that properly stored
coal will lose only 1-2% per year of its energy value due to oxidation.  How-
ever, improper storage was found to result in losses of 3-5% per year.

          Latex Crusting Compounds

          The only protective coating of significance in current use is the
latex crusting compound.  This material is essentially a paint base, and it is
produced by paint manufacturers.  Numerous small firms purchase this material
and resell it as a protective coating for coal or as a surface stabilizer for
earth, sand or other materials stored in stockpiles.  The latex compounds are
normally applied after dilution by a factor of 3/1 to 20/1.  They are sprayed
onto the material to be protected using any equipment capable of spraying water.

          Formulation and Evaluation of Coatings

          During this work, 119 hot-melt formulations and 39 latex mixes were
produced and evaluated.  The types of tests conducted were as follows:

          Visual observation                 Viscosity

               cracking tendency             Density
               surface texture               Thermal expansion

               adhesion to substrate         Water permeability
          Compressive strength               Rheology

          Tensile strength                   Grindability
Not all tests were run on all formulations.  Some tests, such as tensile and
compressive strength, were run on a limited number of specimens to establish
the order of magnitude of the results.  No means of converting strength data
into a useful parameter for characterizing the utility of coatings was iden-
tified.  Thus, the data are of interest primarily as a rceans of estimating
cracking potential.

          Other tests, such as water permeability, effects of thermal cycling
and coefficient of thermal expansion relate directly to the quality of the
coatings.  Tables I and II summarize the results of these tests on formula-
tions that were near the optimum compositions for both the hot-melt and filled
latex coatings.

          Test Panels

          Those formulations which appeared to best meet the above criteria
were cast onto frames, 12" x 12", with about 3-4" of coal as a substrate.

                                      -252-

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                                 Table I.   Physical Properties of Hot-Melt Formulations
CO

ENTRY NO.
2-16-4


2-17-1


2-17-2


5-2-3



6-1-2




VISCOSITY TENSILE PROPERTIES (-30°F) COMPRESSIVE
Avg. KP At Rupture Tangent STRENGTH, (70°F) STRAIN IN DENSITY
RPM Stress Strain Modulus at Failure COMPRESSION GM/cm
COMPOSITION 1 2.5 5 (PSI) (%) (PSI) (PSI) At Failure (%) (70°F)
85.0%
12.0%
3.0%
85.0%
12.0%
3.0%
85.0%
12.0%
3.0%
77.5%
14.9%
3.8%
3.8%
80.0%
15.2%
2.4%
2.4%
Coal 333 1.9
SW 392 Avg 342 1.3
PE 302 1.6
Coal 248 1.8
SW 278 Avg 258 2.1
PE 249 2.1
Coal 148 j 2.2
SW 179 ! Avg 173 1.9
PE 192 J 2.3
Coal 8 7 4 210 0.4 106,000 1.1
SW 79 0.7 18,200
PP
PE
Coal 222 0.4 84,800 1.08
SW 233 0.6 68,200
PP 241 0.5 83,600
PE
      SW = Slack Wax
      PE » Polyethylene
      PP « Polypropylene

-------
                          Table  II.   Characteristics  of  Hot-Melt and Filled Latex Compositions


                        LEAK RATE, %  OF SPRAY          36"  CTE  STRIP          AVERAGE    RESTRAINED
     REFERENCE NUMBERS  70°F   +160°F  -30°F   Shrinkage  Reheat Shrinkage     CTE       ENDS GAP   GRINDABILITY
     5-1-2
            80.0% Coal
            1 T /,<9 OTJ                                                                 _r
             3.3% PE     3'3     8'1     11'°   °'335"            -           7.6  x 10 ^       -           Fair
             3.3% PP

     5-2-3
            77.5% Coal


,             3.8% PP
to
f    6-1-2, 5-30-1

            80.0% Coal
1.4     5.2      8.0   0.305"           -          6.6 x 10~5      -          Fair
            1 5 9? <5W                                                                 -">
             :,"7 JT    14.0    20.0     78.0   0.285"         0.278"        6.2 x 10 D   0.118"        Fair
             2.4 PP

     48
            50.0% Coal
            23.0% Vinyl  ?>?                                                                            Good
                acetate
              copolymer
            27.0% Water
     SW = Slack Wax
     PE = Polyethylene

     PP = Polypropylene

-------
The frames were constructed with wooden pegs spaced at 3/4" intervals around
the periphery.  The pegs served to restrain the coating from shrinkage to en-
hance crack formation and present a more realistic test than would an unre-
strained coating.  The coating was applied in thicknesses ranging from 1/8" to
1/2".  Figure 1 shows two views of a test frame with a hot-melt coating in
place.  Figure 2 shows a cross-section view of the coating on a coal bed.

          The test frames were subjected to a "rainfall" test.  In this test,
the equivalent of 2" of rain was sprayed on the surface of the test panel.
The quantity of water adhering to the surface or passing through the coating
was measured.  For the best coatings, less than 10% of the water was retained
or passed through the coating.  The remainder was repelled and ran off the
coating surface.  The water permeability tests were generally run 3 times, at
ambient temperature and after exposure to temperatures of +160°F and -30°F.

          Thermal Expansion Tests

          Thermal expansion or contraction is an important characteristic of
hot-melt coatings.  If the degree of contraction upon cooling exceeds the
strain-to-failure of a coating material, cracking will result.  Similarly,
if the thermal expansion upon heating exceeds the compressive strain-to-failure,
the  coating will shatter.

          The coatings listed exhibited Coefficients of  Thermal Expansion  (CTE)
ranging from  6 x 10~5 to 14 x 10~5  in/in°F.  Thus,  for a 100°F temperature
change, the degree of expansion  or  contraction would be  about 0.6%  to  1.4%.
The  tensile strain to failure was measured  to be about 0.5%.  Thus,  most coat-
ings would be expected to  crack  upon cooling by 1008F or more.  Heating  does
not  appear to be a problem.  Compressive  strain-to-failure was measured  to  be
about 2%, and none of the  coatings  tested expanded  that  much.

          The CTE is not the only  factor  in cracking  of  the  hot-melt coatings.
The  materials were generally cast  at 200-250°F.   In general, the coatings re-
mained  fluid  until they  cooled  to below 200°F.  They  then start  to  shrink,  if
unrestrained.   Total shrinkage  upon cooling to  70°F ranged from  0.6% to  1.7%.
The  cooling behavior was a function of the  composition,  however.   The CTE
curves  for typical compositions are shown in  Figures  3  and 4.  Formulations
with CTE  values similar to that shown  in Figure 4 would probably be satisfactory
for  stockpile applications.

          Latex Formulation Results

          A  total  of  39  latex  formulations  were prepared and evaluated during
this work.   Included  in this number were four tests of  commercially available
latex crusting compounds  for comparison purposes.   The  remainder of the formu-
lations were filled  latexes,  in which  pulverized  coal was used as an extender
 to improve the waterproofing character of the latexes.

           Some of the latexes  tested were not compatible with coal.  In the
presence  of  coal,  they coagulated or solidifed rapidly.   Daratak SP-1065,
Everflex  GT  and DLR-H resins yielded satisfactory coating films.  All others
 tested were incompatible with the coal.
                                      -255-

-------
Figure 1.  Hot-Melt Coating on Test Frame
                  -256-

-------
Figure 2.  Cross-sectional View of Hot-melt Coating on Coal Bed
                             -257-

-------
                       100
I
ro
u»
oo
                    o
                    r-l

                    X


                    o
                     .  10
H
<
                    W
                    H
                    U
                                                                 FORMULATION 5-1-2
                                                                 80% Coal

                                                                 20% Binder
                                                                     80% Slack Wax

                                                                     20% Virgin Polyethylene
             AVERAGE  CTE

             7.63xlO-5
                                                      PHASE  CHANGE
                                                   105      125


                                                     TEMPERATURE,  °F
                                                        165
185     205
                       Figure 3.  Coefficient of Thermal Expansion Curve for Formulation 5-1-2

-------
    100
10
 o
     10
 tJ



 <
 v^-


 u
    1.0












_ — -7
/
/
^ AVER,
.5











/
/
-T/-
d

AGE CTE
6xlO-5









jrT\
^J
Y

__ 	














U.
X
\
— - r





I
FORMULATI01
77.5% Coal
22.5% Blnd<
66 2/
16 2,
16 2;




L. —
1 ^^
^







__ — _





I
¥ 5-2-3
i
»r —
>3% Slack Wax
'3% Polyethylene
'3% Polypropyleng.




. — . — . -

\
r~°






	





65 85 105 125 145 165 185 2(
TEMPERATURE, PF
5
     Figure 4.  Coefficient of Thermal Expansion Curve for Formulation  5-2-3

-------
          The probable reason for the observed incompatibility is de-emulsifi-
cation of the resin by chemical reaction with ionic components of the coal.
Another possibility is instability resulting from pH change because of acidic
substances in the coal.

          Filled latex coatings made with polyvinyl acetate resins were applied
to 1-ft x 1-ft panels similar to those previously described for the hot-melt
coatings.  All of the coatings were leakers in the "rainfall" test.  The best
of these coatings was an Everflex GT mix with 50% coal, which exhibited only
a 13% leak rate.

          To improve on the leakage rate with latex coatings, several test
panels were made using a specially prepared surface finish on the substrate
coal.  One-half inch of fines, with a particle size of 
-------
                                    MOTOR
                PRESSURE
  HEATER
        STEAM BOILER
                              DRAIN
                                         JACKETED MIXER
P
                                               STEAM

                                              EJECTOR
         I

	I
DISPENSER
Figure 5.   Schematic Diagram:   Coal Cover Application  System
                            -261-

-------
          g)   service lines (heated)

          h)   steam boiler

          i)   dispensing system

          A schematic of the system is shown in Figure 5.  As shown, a mixing
vessel is included in the current subscale apparatus.  This mixer is used as a
batch heater and dispenser.   For larger-scale applications, a continuous sys-
 tem would be more desirable.

          Hot flow application resulted in an excellent layer of coating on an
inclined 4x8 foot panel.  The material thickness varied from 1/8- to 1/4-inch
thick.  Figure 6 shows a technician in the process of coating a 4' x 8* panel.

                                ECONOMIC ANALYSIS

          The following section is an evaluation of the costs and benefits
which would accrue from the use of protective coatings for coal.  Uses of
latex crusting compounds, filled latex coating and hot-melt coatings are
considered.  Both stockpiles and rail car applications are evaluated.  The
steps involved in forming and protecting a stockpile are shown in Figure 7.

          Summary of Stockpile and Rail Car Protection Costs

          Table III shows a summary of the costs of building and protecting a
coal stockpile.  A 250,000 ton stockpile was used as a basis for comparison.
Table IV is a summary of the costs of various techniques for protecting coal
in rail cars.

          Cost/Benefit Analysis - Stockpile Applications

          This section illustrates the benefits to be derived from coal pro-
tection and-the estimated return on investment.  This analysis is based upon
protection of a 250,000 ton stockpile for a period of one year.  The value of
the coal is assumed to be $20 per ton.

          The cost factors used in determining treatment costs are listed
below.

                                                    Cost, $/Ton

          Build and compact pile                        0.08
          Apply latex crusting compound                 0.034
          Apply filled latex coating, 0.025"            0.078
          Apply hot-melt coating, 1/8"                  0.051

          The benefit factors used in determining the return on cost of apply-
ing particular coatings are:
          Reduce  or  eliminate dust  emissions.
          Reduce  or  eliminate leachate formation.
          Maintain or  reduce moisture  content (fuel value effect).
          Minimize freezing  of  coal into  large agglomerates.
          Prevent increase in moisture content (grinder operation).
          Prevent stockpile  migration.
          Reduce  or  eliminate oxidative energy loss.


                                      -262-

-------


                                 %   V'
                                                           '
                                                       ^.
                                                       f
.V -  \
                           tfl

          Figure 6.   Application of Hot-Melt Coatings

-------
Dump  coal  from cars

Grind to <2"

Transport  to pile

Unload on  pile

Form  and compact pile
                     Current practice*

                     unprotected piles
      Latex Crust

1.  Mix with water,
    3-10/1

2.  Spray apply
    4-11 gal/500 ft
        Filled Latex

1.  Grind coal for surface
    preparation *

2.  Grind coal for coating
    mix

3.  Mix coal, water, latex
                        4.  Spray apply 7-31 gal/
                            500 ft2
       Hot Melt

1.  Grind coal for
    coating mix

2.  Prepare wax/plastic
    binder

3.  Heat and mix
    components

4.  Spray apply 20-80 gal/
    500 ft2
* optional
              Figure 7.  Coal Stockpile Formation and Protection
                                     -264-

-------
Table III.  Summary of Stockpile Protection Costs




          Basis:  250,000 ton stockpile
Treatment
Build and Compact
Stockpile
Monitor Stockpile
for 1 year
Latex Crusting
Compound, 1 gal/
200 ft2
Filled Latex on
Surface Fines, .025"
Filled Latex on
Surface Fines, .050"
Filled Latex on
Surface Fines, .100"
Filled Latex on
Normal Surface, 1/8"
Hot-melt on Normal
Surface, 1/8"
Hot-melt on Normal
C,,-*-fn~f> 1 //,"
Time Required
Days
50
365
3.5
13.3
26.6
53.2
11.7
. 11.7
23.4
Total Costs
$
55,000
22,750
8,400
19,500
25,908
42,000
r
33,506
12,788
25,576
Cost/ton
$
0.22
0.091
0.034
0.078
0.107
0.168
0.134
0.051
0.102
                       -265-

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        Table IV.  Summary of Rail Car Protection Costs


             Basis:  1 unit train = 100 rail cars

                     containing 100 ton/car

                     treatment rate = 100 cars/day
        Treatment
Latex Crusting Compound,
1 gallon/500 ft2

Filled Latex on Surface
Fines, .050"

Filled Latex on as Dumped
Surface, 1/8"

Hot-Melt on as Dumped
Surface, 1/8"
Total Cost
     $  '

    700
  3,844


  4,320


  1,355
Cost/ton
    $

   0.07


   0.38


   0.43


   0.14
                            -266-

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          Reduce or eliminate spontaneous ignition.
          Prevent wind or rain erosion.
          Reduce need for snow removal.
          Reduce monitoring costs.
          Reduce fire prevention and extinguishment requirements .

The basis for determining the dollar value or equivalent for these benefit fac-
tors is described in Kromrey, et al. , (1978).  The results are summarized below.

                                                               Total Benefits
                        Treatment Costs,   Direct $ Savings,  Value, Equivalent
_ Treatment _   _ $/ton _   _ $/ton _  _ $/ton _
Compaction                   0.08               0.275              0.61

Latex Crust*                 0.114              0.65               1.09

Filled Latex Coating*        0.158              1.04               1.65

Hot-melt Coating*            0.131              1.04               1.90
   * includes compaction

From this table, the highest return per unit cost occurs by use of the hot-melt
formulation, i.e., return of benefits valued at $1.90 per ton at a cost of
13. lc per ton.

          Cost/Benefit Analysis - Rail Car Applications

          This  section illustrates  the benefits to be derived for protection of
coal in rail cars and the estimated return on investment.   The  results are
based upon  protection of a unit of  100 cars containing 100  tons each of coal.
The value of the coal is assumed  to be $20 per ton.  The benefit factors  con-
sidered are listed below:

          Reduce or eliminate dust  emission.
          Reduce wind losses.
          Prevent moisture increase (fuel value effect) .
          Prevent moisture increase (grinder operation) .
          Prevent freezing of coal  into  large agglomerates.
          Reduce or eliminate spontaneous combustion.

Again, the  basis used to convert  these  factors into  an equivalent dollar  value
is described in Kromrey, et  al. ,  (1978).  The results are summarized in the
following table.
                                                              Total
                        Treatment  Costs,   Direct  $  Savings,  Value,  Equivalent
     Treatment _        $/ton _  _ $/ton _ ___ $/ton _____
Latex  Crust                  0.07                0.54               0.74
Filled Latex  Coating        0.38                0.61               0.81

Hot-melt  Coating             0.14                0.61               1.01

This table indicates the benefit  return per  unit  cost  to  be highest  for  the
latex  crusting  compounds with  $.74  per ton  in benefit value resulting from
costs  of $.14 per  ton.   For  rail car applications, the  latex crust appears  to
be most cost-effective.


                                      -267-

-------
                                  CONCLUSIONS
          Based upon the results of this technical effort,  the following
conclusions are presented:

          1.    Commercially available latex resins used as  coal crusting
               compounds can prevent dust loss and wind erosion, but  do
               not waterproof the coal surface.

          2.    Hot-melt formulations consisting of about 77.5% coal,
               15% slack wax, 3.75% polyethylene and 3.75%  polypropylene
               are capable of sealing a coal surface against water
               penetration.

          3.    A filled latex formulation consisting of 50% coal,
               23% Everflex GT resin and 27% water is capable of sealing
               a coal surface against water penetration provided the
               surface is coated with fines of less than about 1/8"
               particle size.

          4.    Hot-melt coatings appear to be most cost effective for
               application to coal stockpiles.

          5.    Latex crusting compounds appear to be the most cost
               effective means of protecting coal in rail cars.

          6.    The anticipated return in dollars and intangible benefits
               by use of the coal protection methods described herein is
               in the range of 10rl5 times the cost of such protection.
                                     -268-

-------
                                  REFERENCES
ERDA (1975), Report ERDA-TR-120, "The Storage of Solid Fuel at Dumps of
          Thermoelectric Power Stations of the USSR, Methods of Preventing
          Dusting and Spontaneous Combustion of Fuel in Piles."

ERDA (1976), "Energy from Coal," ERDA-TR-76-67, prepared by Tetra-Tech, Inc.
          under Contract No. E(49-18)-2225.

Kromrey, R.V., Scheffee, R.S., DePasquale, J.A., and Valentine, R.S. (1978),
          "Development of Coatings for Protection of Coal During Transport
          and Storage," Final Report on Contract EP-78-C-02-4632., U.S.
          Department of Energy.  Prepared by Atlantic Research Corporation.

Paulson, L.E., Axeley, S.A., Wegert, C., and Ellman, R.C., (1975),
          "Experience in Transportation of Dried Low-Rank Western Coals,"
          Society of Mining Engineers of AIME, Prepoint No. 1 75-B-337.

Wilson, H.S., (1975), "An Update on Coal Storage Technology," Combustion 47,
          33-36 (August).
                                       -269-

-------
 NEW CONCEPTS FOR CONTROL OF FUGITIVE DUST
                     by
             Dennis C. Drehmel
Industrial  Environmental Research Laboratory
   U.  S.  Environmental Protection Agency
   Research Triangle Park, North Carolina
                    and
             Thomas Blackwood
       Monsanto Research Corporation
               Dayton, Ohio

                    and
  S. Calvert, R. 6. Patterson, S. C. Yung
       A1r Pollution Technology, Inc.
          San Diego, California
                     -271-

-------
                                  ABSTRACT

                  NEW  CONCEPTS  FOR  CONTROL  OF  FUGITIVE  DUST

                                       by

              Drehmel, Blackwood, Calvert,  Patterson, and  Yung


     In the vast majority  (92%) of  air quality control  regions  not
meeting total suspended particulate (TSP) standards, fugitive sources
exceed point sources.  In  rural areas, unpaved roads and agricultural
activities are important sources; in urban  areas,  paved roads and construction
sites.  In industrial  areas, both process and  open sources  of fugitive
particles must be controlled not only  for TSP  but  also  for  lead air
quality standards. Hence,  the need  for control of  fugitive  dust requires
technology to span a variety of source types and control requirements.

     Current technology involves improvement in gathering fugitive
process emissions and  prevention of open source fugitive emissions.  One
new concept under study by EPA does neither of these but rather attempts
to capture particles without hooding and evacuation to a control device.
Instead the particles  are  caused to settle out by  introduction  of another
aerosol with appropriate charge and chemical properties.  Another new
concept under study uses a different approach  for  prevention of emissions
from unpaved roads.  Rather than using wetting, oiling, or chemical
treatment, the nature of the roadbed is modified.  Testing  of these
concepts is in an early stage but preliminary  results show  50 to 93%
control is to be expected.
                                     -272-

-------
                  NEW CONCEPTS FOR CONTROL OF FUGITIVE DUST

                                 Introduction

     Among the standards used by the Environmental Protection Agency
(EPA) to prevent adverse health and ecological impacts of air pollution,
is the National Ambient Air Quality Standard (NAAQS).  The NAAQS is
currently expressed in a number of ways involving the limitation of
total suspended particulate (TSP).  Unfortunately, the TSP standard is
not being met in many air quality control regions.  Fugitive dusts
account for most of this problem. In more than nine out of ten control
regions, fugitive emissions are greater than ducted point source emissions.
In one out of three control regions, fugitive emissions are more than 10
times greater than ducted point source emissions.   Within cities the
contribution of point sources is expected to be smaller than fugitive
emissions.  In Philadelphia, more than one-third of the TSP was attributed
to reentrained street dust and vehicular traffic while point sources
were responsible for less than one-fourth of the TSP.

     Because of the importance of fugitive sources in meeting NAAQS, EPA
is involved in a program of control technology research and development.
Re-entrained dust emissions and fugitive process emissions, both described
below, are two ongoing projects which have been labeled "new concepts."
This term does not imply that such technology has not been previously
investigated but rather that the technology has not been fully utilized
and will remain new until it is accepted into conventional practice.

                         Re-entrained Dust Emissions

     Fugitive emissions come from uncontained process emissions or from
the re-entrainment of dust.  For the latter, the problem can be solved
if the surface of the dust can be stabilized and kept free of unscabilized
dust.  The surface may be stabilized by the application of water, oil,
or chemical surface agents.  In the case of unpaved roads, application
of such materials is less cost effective than paving the roads.
Advances in fabric development now provide another possibility to stabilize
a surface; especially, unpaved and haul roads.  Using this approach, an
unpaved road would be covered with fabric and then coarse aggregate.

     The fundamental concept behind use of a fabric roadbed stabilizer,
or "road carpet," for control of fine particle emissions from unpaved
roads is prevention of vortex entrainment by separation of fine roadbed
materials from the coarse aggregate where the traffic movement occurs.
Large aggregate is held from settling, while newly deposited fines
(< 70 ym) are filtered by gravitation and hydraulic action down to a
zone away from vortex entrainment.  Road carpet  can be made from  spunbondedi
thin-film polypropylene on nylon sheet  (Celanese), continuous filament
polyester fibers needled to form a highly permeable fabric  (Monsanto),
or other spun or needle-punched synthetic materials.  The mechanical
interlocking of fibers makes a formed fabric with  the required durability
                                      -273-

-------
and toughness.   Designed  for  road  construction  use,  this  fabric  is  laid
over  poor  loadbearing  soils to  help  support  and contain the  overburden
aggregate.   It  spreads  concentrated  stress from heavy-wheeled  traffic
over  a wider area,  siphons away ground  water, and  contains fine  soil
particles  in the roadbed  that could  otherwise contaminate ballast or
road  overburden.

      Capital  and operating costs differ for  various  control  options.
Although initial  costs  for some control  alternatives may  be  lower than
for road carpet,  maintenance  costs for  these alternatives may  be quite
high. Road carpets  can  add as much as 20% to the cost of  a road  construction,
but the material  will  pay for itself in less than  a year  in  reduced
maintenance  costs and  driver  safety.  In some cases, a new road  can be
built for as  low as 20% of the  cost  of  conventional  roads.

     Treating the road  surface  with  oil  once a  month is an efficient
method of controlling  unpaved road dust emissions.  The estimated cost
of such applications (reported  in 1972)  is $0.10 per square  meter treated
per year.    However, 70% to 75% of the  oil applied moves  from  the surface
of the road  by  runoff and dust  transport, resulting  in ecological harm
caused by the oil or its heavy metal constituents.   Furthermore, surface
oiling does  not  prevent potholes, a  major part  of  road maintenance.

     Roads constructed  using  road carpet, on the other hand, require
significantly less maintenance  because  of the increased road stabilization
imparted by  the  carpet.  The most effective method of reducing particulate
emissions is paving the road  surface; but, owing to high  initial cost
and subsequent maintenance and  repair costs, paving these temporary
roads is impractical.  Road carpet can  be installed to give  a  virtually
permanent, maintenance-free road.

     Use of  road  carpet fabric results  in no health or safety  hazards or
any other unfavorable environmental  impact.  In the development of these
fabrics, various  synthetic polymers  (including  nylon, polypropylene, and
polyester) were  evaluated.  Fabrics  made from any  of these products
generally are resistant to mildew, mild acids,  and alkali, and are rot
and vermin proof.  Polyester was chosen by Monsanto because  of the
following distinct advantages:

          resistance to chemicals, including those found  in  soils
          constant properties over a wide range of temperatures
          high melting point
          little change in wet or dry properties
          low moisture absorption
          high abrasion resistance
          high modulus of elasticity and excellent resilience
          excellent creep resistance

Thus, use of road carpet precludes any environmental damage  due to
leaching of hazardous chemicals or heavy metals.
                                     -274-

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                     Fugitive Process Emissions (FPE)

     Control of fugitive process emissions often has to overcome the
disadvantages of a dispersed, low concentration emission in a large
volume.  If the particulate were not dispersed it could be collected in
a high efficiency hood and ducted to a conventional control device. If
the particulate were of a high concentration or in a building of small
volume, the process building could be evacuated to a conventional control
device.  Assuming that the FPE cannot be hooded or evacuated to a control
device, EPA is investigating the use of chemically and electrostatically
treated water spray droplets.  This method applies to fugitive dust
emissions which cannot be controlled by stabilizing the surface of the
source. Examples are transfer points, conveyor belts, charging operations,
molding lines, and roof monitors.  As always, water with or without
chemical additives can be sprayed to stabilize exposed sources, such as
stock piles which are not being processed.

     Fugitive dust particles entrained in the gas stream may be collected
with charged or uncharged water sprays by mechanisms such as diffusion,
inertial impaction, interception, and electrophoresis.  The larger size
of the water drops would allow easy separation from the gas stream by
methods such as gravitational settling or entrainment separators.

     Figure 1 is a functional diagram for the process anticipated for
controlling fugitive emissions.  The functional phenomena represented in
this diagram could occur concurrently or separately in several types of
equipment.

     Several types of chemicals have been found effective in reducing
fugitive dust emissions when applied to the  source.  Over 100 chemical
products are presently marketed or under development specifically as
dust control agents.  These chemicals act by several different means and
are generally categorized by their composition:  bituminous, polymer,
resin, enzymatic, emulsion, surface-active agent,  ligninsulfonate,        5
latex, etc.  Dust stabilizing agents have been reported in  the literature
and are not being considered in this investigation.

     In addition to the use of surface active agents, the concept  of
using electrostatic sprays involves the controlled  disposal of fugitive
dust that  is entrained in a gas stream.  This approach is the most
permanent  way to control FPE because it precludes  the re-dispersal  of
dust which can  occur  if stabilization is  used or  if the collected  particles
are deposited on the  ground.  After the air  containing the  FPE  is  conveyed
to the  apparatus, it  is necessary  to bring the spray  into  contact  with
the fugitive dust.  The water sprays would be  produced with single- or
two-fluid  nozzles.  Nozzle systems  are  currently  available  on  the  market
which  produce charged water  drops.  Contacting may be obtained  by  projecting
the water  drops  into  the dusty gas  or moving the  dusty  gas  into  the
vicinity of the water drops.  The  water drops  will  be formed  by  hydraulic
pressure sprays.  An  ejector  type  of spray  system is a  likely  candidate
for contacting  with minimum  energy usage.
                                     -275-

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     Containing fugitive emissions with a series of barriers  and/or
 electric  curtains  may prove most cost effective.   The electric  curtains
 would  be  used to deflect the particulate, thus minimizing the volume  of
 air  to be cleaned.   Because of the great variety of FPE source  situations,
 it is  not possible to use a single approach to this part of the system.

     After spraying in the charged water drops,  the next process step
 would  be  to remove the water spray drops after sufficient contacting
 time to effect capture of the initial  fine particles present  in the gas.
 At this stage the  large size and mass  of the water drops is utilized  to
 separate  them from the gas.   An  entrainment separator may be  used for
 this step,  depending on the mist elimination and pressure drop  requirements.
 The  cleaned gas stream leaves the entrainment separator at this point.
 The  water from the entrainment separator is passed through a  separation
 process,  such as a filter,  to remove  the collected dust particles.  The
 water  may then be  recycled  and the dust may be disposed of in such  a  way
 as to  prevent its  re-dispersion.

     The  concept proposed here has some similarity to liquid  scrubbers.
 Recent studies have  shown increased scrubber efficiency can be  obtained
 by electrostatically charging particle  and collectors to opposite polarity.  ''
 Hoenig  has  shown  that naturally  charged fugitive emissions may be
 collected more efficiently  with  charged drops than with uncharged drops.
 The  results  of preliminary  analysis show that this technique  is most
 effective  for small  particles (less than 5 urn diameter).

                            Development  of Concepts

     EPA  has  planned  an extensive  research,  test,  and evaluation program
 for  both  of  these concepts.   The  research portion will  identify parameters
 affecting the  theoretical and economic  limitations to utilization of  the
 technology.   Preliminary  studies  of these parameters will  provide an
 understanding  for optimization.   In the case of  road carpet,  the vortex
entrainment,  comminution, and saltation of material  on  the coarse aggregate
must be modeled.  Size  and  thickness of the aggregate may affect performance.
 For  the charged water sprays,  methods of partial  containment  of the FPE
must be studied as well as  fundamentals of droplet/particle Interactions.

     The test  and evaluation  portion of the program will  involve studying
a prototype of each  new concept.   Using the road  carpet, a 30 to 40
meter  long section of haul  road will be constructed at  a quarry.  A
second  prototype road will  be constructed at a different site to evaluate
subsoil differences.

     The emissions from the  prototype road and a  comparison conventional
road will  be monitored  at several  Intervals of time.   Sampling  will be
conducted when wind  conditions are favorable at  two different vehicle
speeds  and over the  course  of 3 months.   During  this time,  any  changes
 in the mass  reduction or  particle  size  distribution will  be noted and
correlated with observations  on  the condition of  the prototype  road.  The
durability and  other positive attributes of this  type of road construction
will  be evaluated  in  order  to reassess  the economics of this  method of
                                     -276-

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  emissions reduction.   Sampling will be conducted using the quick-reaction
sampler at distances of from 10 to 12 meters from the road.   Since the
sampling can be conducted over short periods of time (4 to 10 minutes),
desirable wind direction, speed, and atmospheric stability can be chosen
for sampling (i.e., mid-day and approximately perpendicular to the
road).

     The test and evaluation program for the charged water sprays will
consider the following parameters:

          1.   Air flow rate--three levels.
          2.   Air temperature--two levels.
          3.   Particle type--two levels.
          4.   Particle size distribution--two levels.
          5.   Water-to-air ratio.
          6.   Water pressure.
          7.   Nozzle type and arrangement.
          8.   Electrostatic charge level.
          9.   Surfactant concentration.
         10.   Confinement type.
         11.   Wind conditions (windy and calm).

The spray contactor will be 1.8 m high and 2.5 m wide and attempt to
collect metal oxide or liquid aerosols.  Sampling will  be by total
filters, cascade impactors, and light scattering devices.

                                Conclusions
     Two concepts for control of fugitive emissions have been identified
and will be investigated under an EPA program.  One concept employs road
carpet to stabilize unpaved roads by separating traffic from entrainable
particles. The second employs charged water sprays for direct collection
of fugitive process emissions.

                                References
     1.   Carpenter, B. H. and Weant, G. E., Fugitive Dust Emission and
Control, Symposium on the Transfer and Utilization of Particulate Control,
July 24-28, 1978, Denver, Colorado.

     2.   Bradway, R. M., Record, F. A. and Belanger, W. E., A Study of
Philadelphia Particulates Using Modeling and Measurement Techniques,
Symposium on the Transfer and Utilization of Particulate Control,
July 24-28, 1978, Denver, Colorado.

     3.   Evans, J. S., Schneider, M., Cooper, D. W., and Quinn, M.,
Setting Priorities for the Control of Particulate Emissions from Open
Sources, Symposium on the Transfer and Utilization of Particulate Control,
July 24-28, 1978, Denver, Colorado.

     4.   Ochsner, 0. C., Chalekode, P. K. and Blackwood, T. R., Source
Assessment:  Transport of Sand and Gravel, EPA-600/2-78-004y (in print),
USEPA, Cincinnati, Ohio, October  1978.
                                     -277-

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     5.   PEDCo, Investigation of Fugitive Dust-Sources, Emissions, and
Control:  Volume I.  EPA-450/3-74-036a, June 1974.

     6.   P1lat, M. J. et al..  ES&T, 8: 360-362, 1974.

     7.   P1lat, M. J. et al., JAPCA, 25: 176-178, 1975.

     8.   Hoenlg, S. A., Use of Electrostatically Charged Fog for Control
of Fugitive Dust Emissions, EPA-600/7-77-131 (NTIS No. PB 276645),
November 1977.
                                     -278-

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         WATER
         DROPS
ro
        FUGITIVE
        PARTICLE
        EMISSIONS
CONTACT OUST
WITH SPRAYS
COLLECT DUST
 ON DROPS
SEPARATE DROPS
  FROM AIR
                                    Controlled  Disposal of  Particles
                                                                    DISPOSE
                                                                     OP
                                                                     DUST
                                                                                                 CLEAN
                                                                                                  AIR
                                                                  DISPOSE OF
                                                                  OR RECYCLE
                                                                    WATER
                        Figure 1.
         Functional  diagram   for  the major process steps
         involved in controlling  fugitive  particle emissions
         with  a charged drop system.

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              BEST AVAILABLE CONTROL  TECHNOLOGY  (BACT)  FOR
              FUGITIVE EMISSIONS CONTROL IN THE  STEEL  INDUSTRY

              AUTHOR:   Arthur G. Nicola
                       Manager,  Air Pollution Control  Systems
                       PENNSYLVANIA ENGINEERING  CORPORATION
                       PITTSBURGH,  PENNSYLVANIA
                                ABSTRACT
       Technology for controlling fugitive emissions related to the various
steps in iron and steelmaking have been given low priorities in the past
due to light concentrations as well as the difficulty in collecting these
emissions with the result that the state-of-the-art for controlling fugitive
emissions in the steel industry has lagged behind the technology developed
in other areas.  In some cases, such as blast furnace cast house emission
control, this technology is virtually non-existent in the U.S.

       Since the technology for emission reduction through gas cleaning
already exists and can be accomplished by any number of air pollution
control devices, the limited scope of this paper will concentrate on the
best available technology for collecting fugitive emissions from the major
sources which include:

       1)  Blast furnace           - cast house
       2)  Oxygen steelmaking      - hot metal charging, tapping
                                     ladle alloy additions, reladling
       3)  Electric Furnace Shop   - charging and tapping

       The ideal solution appears to be collection of the fugitive emissions
at their source preventing their escape into the atmosphere, which allows
emission control with minimum volumes at lowest capital investment and
operating cost.

       Although collecting the emissions at their source has not always been
the most practical method in the past, due to interference with normal
operations, present day technology is gradually overcoming these obstacles,
allowing systems that collect the emissions at their source to be  installed
in operating shops.
                                   -281-

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                 BEST AVAILABLE CONTROL TECHNOLOGY (BACT)
            FOR FUGITIVE EMISSIONS CONTROL IN THE STEEL INDUSTRY
 INTRODUCTION

 BLAST FURNACE  CAST  HOUSE EMISSION CONTROL

 Tap Hole
 Trough
 Runners
 Hot Metal Cars
 Slag Pots

 FUGITIVE EMISSION CONTROL DURING  THE OXYGEN STEELMAKING  PROCESS

 Hot Metal Charging
 Scrap Charging
 Tapping
 Slagging
 Puffing During Oxygen Blow

 HOT METAL RELADLING

 FLUX HANDLING
ELECTRIC FURNACE SHOP FUGITIVE EMISSION CONTROL

Charging
Tapping

CONCLUSION
                                   -282-

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Figure 1    Cast House Arrangement

Figure 2    Multiple Tap Hole Cast House Arrangement

Figure 3    Retractable Curtains In The Cast House

Figure 4    Hot Metal Car

Figure 5    Hot Metal Charging For Basic Oxygen Process

Figure 6    Schematic Arrangement Of EOF Furnace Enclosure

Figure 7    Components Effecting Fugitive Emission Control With
            Furnace Enclosure

Figure 8    Recent EOF Installation With Fugitive Emission Control

Figure 9    Hot Metal Charging Emission Control With Furnace Enclosure

Figure 10   Schematic Arrangement - Ladle Hood For Reladling Emission
            Control

Figure 11   Reladling Emission Control - Pouring Through A Vertical
            Slot In The Ladle Hood

Figure 12   Schematic Flow Diagram - Pollution Control System For
            Electric Furnace Shop

Figure 13   Fugitive Emissions During The Tapping Operation

Figure 14   Typical Furnace Enclosure For Electric Furnace

Figure 15   Charging Operation With Furnace Enclosure

Figure 16   Tapping Operation With Furnace Enclosure
                                    -283-

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                ."BEST AVAILABLE CONTROL TECHNOLOGY  (BACT)
          FOR FUGITIVE EMISSIONS CONTROL  IN THE STEEL  INDUSTRY"
 Introduction

 Current air pollution control regulations dictate that the Best
 Available Control Technology  (BACT) be utilized for controlling
 fugitive emissions in the  Iron and Steel Industry.  These emissions
 can be generally divided into two (2) categories - open dust sources
 and process fugitive emissions.  Open dust source fugitive emissions
 include those sources from which emissions are generated by the
 forces of wind and machinery acting on exposed aggregate materials,
 while process fugitive emissions include uncaptured particulates and
 gases that are related to  the various steps in the iron and steelmaking
 process.

 Since air pollution is associated with practically all steps of iron
 and steel production, the related air pollution control equipment is
 an important factor in all of these operations.  A production process
 may become obsolete if it is not capable of meeting today's stringent
 air pollution control requirements.

 Technology for controlling fugitive emissions related to the various
 steps in iron and steelmaking have been given low priorities in the
 past due to light concentrations, as well as the difficulty in
 collecting these emissions with the result that the state-of-the-art
 for controlling fugitive emissions in the steel industry has lagged
 behind the technology developed in other areas.  In some cases, such
 as blast furnace cast house emission control, the technology is
 virtually non-existent in the United States.

 Since the technology for emission reduction through gas cleaning
 already exists and can be accomplished by any number of air pollution
 control devices, the limited scope of this paper will concentrate on
 the Best Available Control Technology (BACT) for collecting the process
 fugitive emissions generated by the main metallurgical production
processes which include Blast Furnaces, Basic Oxygen Steelmaking and
 Electric Furnaces.

 The alternatives for collecting fugitive emissions generated during
 the main metallurgical processes are generally limited and usually
have many disadvantages.

 The ideal solution of collecting fugitive emissions at their source
 to prevent their escape into the atmosphere, allowing emission control
with minimum volumes at lowest capital investment and operating cost,
 is normally the most difficult system to install.
                                  -284-

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Collecting fugitive emissions at their source has not always been the
most practical method in the past due to possible interference with
normal operations; present day technology is gradually overcoming these
obstacles, allowing systems that collect the emissions at their source
to be installed in operating shops.

BLAST FURNACE CAST HOUSE EMISSION CONTROL

The cast house structure surrounding the blast furnace, encloses the
runners and operating area and provides weather protection for the
operators and equipment (Figure 1).  At the same time, this enclosure
also contains the fumes generated during the cast.  Since environmental
control efforts have been concentrated in other areas, blast furnace
cast house emission control has been given a low priority with the
result that little has been done to date to control these cast house
emissions in the U. S.

In the U. S. today, there are 184 blast furnaces producing basic iron
with 3 new blast furnaces scheduled to start up in the near future.
However, none of the operating blast furnaces are capable of meeting
current air pollution control regulations.  It is anticipated that in
the future, all new blast furnaces will be required to incorporate cast
house emission control and existing blast furnace cast houses will be
required to install some degree of cast house emission control.

Virtually all blast furnace cast house emission control technology to
date has been developed by the Japanese.  During the past ten  (10)
years, they have developed their systems to the point where they now
have integrated their ironmaking and emission control.  At the present
time, one-hundred percent  (100%) of the blast furnaces in Japan have
some degree of cast house emission control.

Primarily, the Japanese approach is to capture the fumes at their source,
preventing their escape into the atmosphere.  This is accomplished by
close fitting hoods and covers wherever the hot metal is exposed to the
atmosphere in the cast house.  At  the same time,  the Japanese often
employ a separate secondary system consisting of  canopy or monitor hoods
for scavenging and building evacuation.

Particulate emissions from cast houses in the U.  S. have been  found to
be in the range of 0.2 to  0.6 Ibs./ton of hot metal cast.  However,  in
Japan, particulate emissions have  been found to exceed 1.0  Ibs./ton of
hot metal cast.   In general, these emissions are  approximately 751 iron
oxide with small percentages of manganese,  silicon oxides and  sulphites.
Differences in the levels  of fume  generated from cast house to cast
house can be attributed to the variations in operating practices and
materials used in the blast furnace  cast house.
                                   -285-

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 Sources  of fugitive  emissions  in the blast  furnace cast house are the
 tap hole,  trough,  runners,  hot metal cars and slag pots.  These areas
 generate practically all of the  fugitive emissions associated with cast
 house  operation.   Existing  cast  house  installations  in the U. S. offer
 many problems  in adopting Japanese technology.  However, the new blast
 furnaces with  multiple tap  holes scheduled  to start  up in the U. S. in
 the near future are  incorporating Japanese  technology for cast house
 emission control (Figure 2).

 Tap Hole

 The primary source of fugitive emissions in the cast house is from the
 hot metal as it exits  the  blast furnace at the tap  hole.  Approximately
 30% to 401 of  the total fugitive emissions  can be attributed to the tap
 hole.  With the Japanese technology, these  fumes are normally controlled
 with local hoods or  retractable  curtains (Figure 3).

 Trough

 The hot metal pool adjacent to the tap hole normally extending to the
 dam and skimmer (25' to 50' long x 3'  to 4' wide x 2' deep) serving as
 a holding pit  to separate the  hot metal and slag, is also a major source
 of emissions in the  cast house.   The fumes  here are  effected by the area
of hot metal exposed to the atmosphere, temperature  of the hot metal,
 type of refractory used, and other factors.   Operating systems collect
 these emissions with the tap hole fumes utilizing a  retractable curtain.

Runners

Emissions from the runners  are also dependent on the pool areas exposed
 to the atmosphere and the metal  temperature.   As the metal cools, carbon
emerges from the saturated  solution as "Kish", a form of graphitic
carbon that is light and flaky.   These emissions can be controlled by
replaceable refractory lined runner covers.

Hot Metal Cars

Molten metal from the runner spouts is poured into the hot metal cars
 located outside of the cast house or in arcade under the cast house
 floor  (Figure  4).  The density of these fumes is dependent on the rate
 of cooling of  the hot metal.   Local hooding can normally be utilized to
 control these  fumes  since the  hot metal cars  are always in the same
 relative position during this  operation.
                                  -286-

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Slag Pots

Fumes generated here are the result of running the slag into refractory
lined slag pots or a pit adjacent to the cast house and can be readily
controlled with local hoods.

Since the installation of cast house emission control systems must have
a minimal impact on established operating practices and at the same time
maintain high safety standards on the cast house floor, transfer of
Japanese technology for blast furnace cast house emission control in
the U.S. is not a simple matter due to the difference in operating
practice as well as cast house geometry.  Tap hole restrictions, number
of pouring stations, runner layout and pouring station geometry are all
limiting factors on the majority of older blast furnaces with rated
capacities of 2,000 tons/day or less.

The alternative of building evacuation requiring 45-80 air changes per
hour is a costly solution to the cast house emission control problem.

FUGITIVE EMISSION CONTROL
BASIC OXYGEN STEELMAKING SHOP

In the EOF Shop, a number of sources exist which generate fugitive
emissions that are not captured by the main gas cleaning system during
the oxygen blowing process.  Today, collection of these fugitive
emissions has become more of a concern than the primary gas cleaning
itself.  This concern for fugitive emission control is based on the
difficulty of efficient fume collection at the emission source, since
once the fume escapes into  the building, it is almost impossible to
control.

In an effort to comply with current air pollution control regulations,
many systems of different design have been installed and are in
operation today with varying degrees of success.  However, to success-
fully control fugitive emissions with minimum capital expenditure, they
must be collected at the source and not allowed to escape into the
building.

Major sources of fugitive emissions  in the basic oxygen steelmaking
process are scrap charging, hot metal charging, tapping and ladle alloy
additions, slagging, puffing during  the oxygen blow and flux handling.
Other sources such as ladle transporting and teeming also contribute
to fugitive emissions, but  these are low in volume and dissipate readily.
They normally do not contribute to monitor emissions from the  EOF  Shop.
In general, fugitive emissions from  the EOF Shop are effected  by a
number  of factors and can be substantial.  However, the particulate
loading is relatively low.
                                    -287-

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Hot Metal Charging

The worst condition occurs during charging of hot metal into the
furnace which already contains scrap.  The hot metal and the effect of
the hot metal on the scrap both contribute to emissions during this
period (Figure 5).  Test results have shown that fumes generated at
this time are composed of approximately 35% iron oxide, 30% kish and
others, with participate size less than 100 microns and an approximate
emission rate of 0.3 to 0.4 Ibs. per ton of hot metal poured.

Since the prime factors controlling fume generation during this period
are the condition of scrap and the rate of hot metal poured, operating
practice is a big factor in the amount of fumes generated.

Scrap Charging

Scrap charging itself is not a primary source of pollution, however,
when the scrap contains a foreign substance such as dirt, paint or
oil, it becomes a major pollution source when the hot metal is added.
The quantities of pollution generated during scrap charging itself
are minor compared to the fumes generated during hot metal charging and
can be minimized by scrap selection.

Tapping

A dense fume normally results from the tapping operation itself and
with ladle additions such as ferro silicon and ferro manganese, the
magnitude of the problem increases.  Fume composition here is dependent
on the alloys employed but generally would consist of approximately
75% iron oxide with particle size less than 10 microns and an average
emission rate of 0.15 to 0.20 Ibs. per ton.

Slagging

Emissions from the furnace slagging operation can be a major problem
depending on the type of steel being produced since it influences the
slag volume and emission rate at this time.  The method of killing the
slag is also a factor which influences the emissions during the slagging
operation.  Fumes are generated inside the furnace at this time and
continue with the slag as it falls inside the slag pots below the
charging floor.  These emissions normally have a particle size less than
100 microns.

Slagging fumes are relatively cold and do not have the necessary thermal
energy to cause the fumes to rise into an overhead canopy hood making
them difficult to capture.
                                   -288-

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Puffing

Puffing during the oxygen blow occurs intermittently.  When this occurs,
generally small quantities of fume are emitted around the mouth of the
furnace.  This is not a major source of fugitive emissions, however, it
does contribute to the total emission problem in the shop.

Methods of Collection

With present technology, the alternatives available for collecting the
oxygen steelmaking fugitive emissions are:

1.  Complete or partial building evacuation.
2.  Local hoods and dampers.
3.  Furnace enclosures.

Canopy hoods located in the building trusses for partial or complete
building evacuation systems are operating in a number of shops with
varying degrees of success.  In most cases, this method is normally
considered as a last resort due to the high capital expenditure and
operating cost involved.  However, these systems usually are given
favorable consideration by maintenance and operating personnel since
they require minimum maintenance and do not restrict operating practices.
Volume requirements to achieve the necessary collection efficiency with
a canopy hood system, would normally be in excess of 1,000,000 CFM for
complete building evacuation.

Local hoods appear to be more effective than canopy hoods  in collecting
these emissions, since they are in closer proximity to the emission
source.  However, relatively high volumes are still required to
effectively collect fugitive emissions in this manner.  Local hoods are
also undesirable from the maintenance and operating point  of view.
Dampers utilized to direct charging emissions into the main gas cleaning
hood have also experienced only limited success to date.

Collection of fugitive emissions by means of a furnace enclosure has
proven  to be the most economical solution, as well as the  Best Available
Control Technology  (BACT) since it allows collection of emissions at  the
source  and prevents their escape into the atmosphere.  With properly
designed furnace enclosures, it has been demonstrated that it is possible
to  effectively control  scrap charging, hot metal charging, furnace
tapping, ladle alloy additions, furnace slagging and puffing emissions
with low volumes.  At the present time, systems of this type are doing
an  effective job of fugitive emission control with volumes of
approximately 350,000 ACFM.
                                  -289-

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 The  EOF furnace enclosure  (Figure  6)  essentially forms  a  gas  tight  seal
 when the bi-parting doors  are  closed.   Since  the furnace  enclosure
 extends below the  charging floor,  the only openings  are for the  ladle
 car.   If desired,  the  ladle car openings  can  be  effectively reduced by
 air  curtains  or the addition of a  vertical shield on the  end  of  the
 ladle car, as a means  to increase  the efficiency of  the furnace  enclosure
 during tapping.

 The  furnace enclosure  design is based on  sound engineering principles
 and  actual testing,  taking into consideration the volume  of fumes
 generated inside the furnace due to the reaction of  pouring hot  metal
 into the furnace,  as well  as the velocity and temperature of  the fumes
 leaving the mouth  of the furnace (Figure  7).

 During charging, the bi-parting doors  are opened while  charging  scrap
 or pouring hot metal and the fumes are collected through  the  secondary
 hood located  inside  the enclosure  directly above the furnace  mouth.
 For  controlling  emissions  during all other phases of operation,  the
 enclosure doors  are  closed,  while  the  fumes are  evacuated from the
 enclosure through  the main or  secondary hood.

 With a properly  designed furnace enclosure,' it is possible to collect
 secondary emissions  generated  by the basic oxygen process with
 approximately 901  efficiency,  provided the charging  of  hot metal into
 the  furnace is done  at a controlled rate  and  the scrap  is relatively
 clean.

 One of the more  recent EOF  installations with effective fugitive
 emission control facilities  (Figure 8)  incorporates  individual furnace
 enclosures over  two  (2) 350  ton  vessels, with the main  gas cleaning
 systems being utilized for  secondary emission control (Figure 9).

 Practically all new BOF/Q-BOP vessels  that have been  installed in the
U. S.  in the past  seven (7) years have  included a partial or full
furnace enclosure  for fugitive emission control.   Since the original
enclosure designs had many deficiencies, these systems are operating
today with varying degrees of success.  At the present time, however,
 there are approximately ten  (10) installations operating  or in the
 construction stage which incorporate the secondary hood inside the
 furnace enclosure with sufficient volume for  effective fugitive emission
control being provided by the main gas cleaning or an auxiliary system.
                                  -290-

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The first retrofit fugitive emission control system incorporating
furnace enclosures for controlling emissions has been installed in an
operating EOF Shop without interrupting normal production, demonstrating
that it is possible to install such equipment without disrupting normal
production schedules.  In this case, an existing baghouse system was
utilized for gas cleaning.

Hot Metal Reladling

The hot metal reladling operation is another primary source of fugitive
emissions in the oxygen steelmaking process.  The fumes generated
during hot metal reladling consist of approximately 55% iron oxide
less than 3 microns, 42% graphite greater than 75 microns and 3% others
with an approximate emission rate of 0.25 Ibs. per ton of hot metal.
With today's technology, collection of reladling emissions is not a
problem since it is possible to utilize local hoods or close fitting
ladle hoods depending on the arrangement of the reladling facility.

The main factors effecting the collection of reladling emissions is
the distance of the hood from the ladle mouth, as well as the rate of
pouring hot metal.  In actual practice, since the handling time remains
almost constant regardless of the amount of hot metal handled, the
volume required to control reladling emissions with a canopy or local
hood is proportional to the volume of hot metal.

In contrast, utilization of a close fitting refractory lined ladle hood
for collecting the reladling emissions allows fume collection at the
source.  The close fitting refractory lined ladle hood (Figure 10)
utilizes the "air seal" principle where the fumes are drawn through a
pouring slot in the hood and the gap between the hood and the ladle with
sufficient velocity to prevent fumes from escaping into the atmosphere.

Actual efficiency of the ladle hood has been demonstrated by a recent
installation (Figure 11) where the reladling emissions for a 350 ton
furnace are effectively collected with 125,000 CFM.  In this design, the
hot metal is poured through a vertical slot in the movable ladle hood
which serves two  (2) reladling stations.  It  is estimated that canopy
or local hoods would require volumes in excess of 300,000 CFM to
effectively collect these emissions.

Flux Handling

Flux handling also contributes to  total fugitive emissions in the  EOF
Shop, but these emissions are minor in nature and easily controlled.
                                   -291-

-------
 FUGITIVE EMISSION CONTROL
 ELECTRIC FURNACE SHOP

 Fugitive emissions associated with the electric  furnace  shop  are mainly
 charging and tapping  emissions which are  usually heavy and difficult  to
 capture.   Today,  a typical  emission control  system for an  electric
 furnace  would normally consist O-F Direct  evacuation or side draft hoods
 for  the  primary gas cleaning with canopy  or  local hoods  for collecting
 charging and tapping  emissions (Figure 12).   Total emissions  from
 electric furnaces producing carbon steel  are approximately 30 Ibs./ton
 of steel produced with approximately 3 to 5  Ibs./ton associated with
 charging and tapping  emissions, while the particulate loading for
 electric furnaces melting alloy steel is  approximately one-half
 of the emissions  generated  by carbon steel furnaces.

 Charging Emissions

 Charging emissions resulting from charging a hot electric  arc furnace
 with scrap are  usually heavy and  difficult to capture.   The intensity
 of the charging emissions is a function of scrap cleanliness.  Scrap
 containing heavy  rust,  oil,  grease or dirt produces  heavy  emissions
 during charging.   These emissions are highly carbonaceous  consisting
 primarily of smoke and soot.

 Tapping  Emissions

 Tapping  emissions generated while pouring steel  from the furnace into
 the  ladle  are primarily composed  of metallic oxides  resulting from
 contact with the  air  and from bath agitation.  Tapping fumes,  like
 charging emissions, are also  difficult to capture  (Figure  13).

Methods of Collection

With present technology, the  alternatives  available  for  collecting
charging and tapping emissions are  complete or partial building
evacuation and local hoods,   in addition to partial or full furnace
enclosures.

Today, most electric furnace  shops utilize canopy hoods  for charging
and tapping emission control.  Although they  offer little operating
restrictions, they have the disadvantages of high volume requirements,
high capital and operating costs and result  in poor working conditions
due to the shop atmosphere.
                                   -292-

-------
Local hoods have achieved some degree of success for collecting tapping
fumes.  However, operating practices do not allow the installation of
local hoods for collecting charging emissions.

Based on the success in collecting fugitive emissions in the EOF Shop
with furnace enclosures, the alternative of collecting Electric Furnace
Shop fugitive emissions by means of a furnace enclosure offers a
practical solution.  Although the furnace enclosure offers an efficient
and economical solution to the problem, objections from operating
personnel appear to be a big obstacle.

While the furnace enclosure technology applied to electric furnaces
is still in its infancy, an electric furnace shop consisting of two  (2)
60 ton arc furnaces, utilizing complete furnace enclosures for total
emission control, has been operating since 1976 without adversely
effecting their operating practices.

The typical furnace enclosure  (Figure 14) essentially forms a gas
tight enclosure from which the fumes are evacuated.

During the charging operation, the bi-parting doors are opened to
allow entry of the scrap bucket  (Figure 15).  After positioning the
scrap bucket, the bi-parting doors are closed and the scrap is charged
into the open furnace.  The fumes generated at this time are evacuated
from the enclosure for gas cleaning.

During the tapping operation,  the bi-parting  doors are closed while
the fumes are evacuated from the enclosure  (Figure 16).

In addition to offering the Best Available Control Technology for
electric furnace shop emission control, the furnace enclosure offers
many  other advantages,  including effective  emission control with  low
volume requirements, collection of emissions  at  their  source, lowest
capital  investment and  operating costs, improved working conditions
and a practical solution  for sound control  in electric furnace shops.

The Texas Air Control Board recently made  an  analysis  of electric
furnace  shop emission control  systems with total emissions control
in the State of Texas since 1972.  Utilizing  a  ventilation index
developed by the Texas  Air Control Board to grade the  various  systems,
the  furnace enclosure had the  lowest index number proving  to be the
most  efficient  installation.
                                  -293-

-------
 CONCLUSION

 Technology for fugitive  emission control has  lagged behind  the
 technology developed for main gas cleaning  systems  in the Iron and
 Steel  Industry because the  fugitive emissions were  considered minor
 in comparison  to  the emissions generated during  the actual  melting
 periods, and the  fact that  regulatory authorities were willing to
 tolerate these emissions while concentrating  on  other fnore  important
 areas.  As a result,  at  the present time, system applications for
 fugitive emission control have not reached  the same degree  of
 reliability.

 This gap in technology is gradually closing due  to  current  pressure
 by the regulatory authorities  to  control all  fugitive emissions.  This
 is evidenced by the  evolution  of  the  total  furnace  enclosure for
 controlling fugitive  emissions  from oxygen  steelmaking facilities and
 electric furnace  shops and  development of the close fitting ladle hood
 for controlling reladling emissions.

 With present day air pollution  control regulations, new technology
 will undoubtedly be developed  for blast furnace  cast house  emission
 control.   Proven Japanese technology with modifications to  accommodate
 U. S. operating practices and cast house geometry appears to be a
practical  solution.  Two (2) new  blast furnaces  scheduled to start up
 in the near future in the U. S. will  incorporate Japanese technology
 for cast house emission control.

The Best Available Control Technology (RACT)  for fugitive emission
control that will be acceptable to the Iron and  Steel Industry
requires a technology that offers the most  effective and economical
type of fugitive emission control from the  standpoint of working
environment which will allow these emissions  to  be  collected at their
source and prevent their escape into the atmosphere.
                                  -294-

-------
References

1.  Blast Furnace Cast House Emission Control Technology Assessment,
    EPA-600/2-77-231 (Nov. 1977).

2.  Inspection Manual For Enforcement Of New Source Standards For
    Producing Electric Arc Furnaces. EPA 540/1-77-007 (May 1977).

3.  A Regulatory View Of Air Pollution Controls On Electric Arc
    Furnaces In Foundries And Steel Mills In Texas by James C. Caraway,
    Texas Air Control Board, Austin, Texas.
                                  -295-

-------
         Typical open cast house
     with crane parallel to iron trough
Iron Trough
& Skimmer
  Hot Metal
   Runners
 Hot Metal
      Cars
                    PLAN
                  Section A-A

 Figure 1 - Cast House Arrangement
Slag
Runner
Slag Pits
                                       Crane
Slag Pits
                       -296-

-------
I
NJ
VO
                          Blast Furnace
                                                    Slag Pits
               Iron
               Runners
Slag Runners
                          Tilting Spout'
                          Enclosure
         Typical cast house 10,000 ton day furnace capacity
      Figure 2 - Multiple Tap Hole Cast House Arrangement

-------

     Iron
     Runner
to
10
oo
     Runner

                                               Retractable enclosure
                                               over tap hole,iron
                                               trough & skimmer
                                O
Enclosure take-off
duct to  control
device
                     Plan view single tap hole furnace
                     partial emission control concept
                     Figure 3 - Retractable Curtains in the Cast House

-------
Figure 4 - Hot Metal Car

-------
    I
   OJ
   o
   o
Figure 5
Hot Metal Charging For

Basic Oxygen Process

-------
   BUMPER
   SECONDARY HOOD
   HOT METAL CHARGING LADLE
   FURNACE CHABONG DOORS
        (Retractable)
   SLAG POT
 I
o
t-1
WATER COOLED HOOD
HOOD TRANSFER CAR
ADJUSTABLE SKIRT
TAPPING EMISSIONS DUCT
SEAL RING
FURNACE ENCLOSURE
OPERATING FLOOR
TEEMMG LADLE
                                                                                                 SHOP MR INDRAFT
                                                                                                       SLAGGMG&
                                                                                                     TAPPING
         ^••^•^••^^^••••^^^^^•^^^^•iH^^HBBMH^^HMMHMMi^^HB^^HMVMHMB^^^HBHHM^^HBMH^HBMHHHBBMHaHHBiHBHH

          Figure 6  -  Schematic Arrangement  For BOF Furnace Enclosure

-------
                   FURNACE  ENCLOSURE

Figure 7 - Components Effecting Fugitive Emission Control
       With Furnace Enclosure

-------
Figure 8 - Recent EOF Installation
           With Fugitive Emission
           Control

-------
Figure 9 - Hot Metal Charging
           Emission Control With
           Furnace Enclosure
-304-

-------
     TORPEDO CAR
LADLE HOOD
 i
 u>
 o
 VJ1
HOT METAL LADLE
 Figure 10 - Schematic Arrangement - Ladle Hood For Reladling Fjnission Control

-------
Figure 11 - Reladlin
KeJ.aaj.ine: hmi
Pouring Throu
Slot In The i
hmission Control
      A Vertical
     le Hood

-------
                                   SCHEMATIC FLOW DIAGRAM
                                   GAS CLEANING SYSTEM FOR
                                     ELECTRIC ARC  FURNACE
      ROOF CANOPY HOOD
i
u>
o
                                   WATER COOLED
                                      ELBOW
                SCRAP CHARGING
              TAPPING
                           ELECTRIC ARC FURNACE
                                        REVERSE AIR FAN
                                                   BAG FILTER (PRESSURE TYPE BAG HOUSE)
  Figure 12 - Schematic Flow Diagram - Pollution Control System For Electric Furnace Shop

-------
higure 13 -  Fugitive Emissions
            During The Tapping
            Operation
-308-

-------
Figure 14 •  Typical Furnace
            Enclosure For
            Electric Furnace

-------
Figure 15 •  Charging Operation
            With Furnace Enclosure

-------
ure  Hi  -  T;i|       Iperal ion
          With  1'iirnace l!n<
-311-

-------
     CONTROL OF  FUGITIVE EMISSIONS

       AT  REVERBERATORY FURNACES

            AND  CONVERTERS
                   by

       Alfred B.  Craig, Jr., IERL
  U.S.  Environmental  Protection Agency

                  and

L.V. Yerino, R.T. Price, and T.K. Corwin
        PEDCo Environmental, Inc.
            October 24, 1978
                 -313-

-------
                                 DISCLAIMER


     This paper was prepared by PEDCo Environmental, Inc., for presentation at
the Third Symposium on Fugitive Emissions in San Francisco, California, on
October 24, 1978.  Information was collected under Industrial Environmental
Research Laboratory's program on fugitive control (U.S. EPA Contract No.
6802-2535, Task 1).  The opinions, findings, and conclusions expressed are
those of PEDCo Environmental and not necessarily those of the U.S. Environ-
mental Protection Agency.


                                 ABSTRACT

     The following are discussed in this paper:  the functions of the rever-
beratory and converter furnaces; methods of charging, operations, slagging,
tapping of each type of furnace, and their related emissions during these
operations; methods of controlling the fugitive emissions during the afore-
mentioned operations; relative merits and efficiencies of the different
methods of controlling fugitive emissions and costs; types of furnaces avail-
able and their relative fugitive emissions in comparison with each other; and
possible future types of furnaces to minimize emissions.
                                    -314-

-------
               CONTROL OF FUGITIVE  EMISSIONS  AT  REVERBERATORY
                           FURNACES AND CONVERTERS
Summary

Introduction

A.   Copper Smelting Furnaces
     1.   The Smelting Process
          a.   The Reverberatory Furnace
          b.   The Electric Furnace
          c.   The Flash Furnace
          d.   The Noranda Furnace
     2.   Fugitive.Emissions - Smelting Furnaces

B.   Copper Converters
     1.   The Converting Process
          a.   The Pierce-Smith Converter
          b.   The Hoboken Converter
     2.   Fugitive Emissions - Converters

C.   Discussion of Fugitive Emission Controls/Practices
     1.   Smelting Furnaces

D.   Relative Merits and Efficiencies of Different Methods of
     Controlling Fugitive Emissions - Converters

E.   Costs  of Fugitive Emission Control Systems
     1.   Cost Parameters - Secondary Hooding
     2.   Capital  Costs
     3.   Operating Costs

F.   Current and Possible Future Methods/Processes For Emission Control
                                     -315-

-------
                                    SUMMARY


      In  terms of domestic consumption, copper is the largest of the three
 primary  nonferrous metals (lead, zinc, and copper).  In 1976, about 1.33
 million  metric tons of copper were produced in the 16 U.S. smelters from
 domestic ores, and 1.8 million metric tons from domestic and foreign ores.
 Vast  amounts of particulate and sulfur dixoide (S02) emissions are generated
 in  producing this tonnage of copper.  Copper smelters are a major source of
 S02,  emitting approximately 80 percent of the total amount of S02 emitted from
 the copper, lead, and zinc industries.  The industry is implementing control
 methods  to recover some of the S02 as a marketable product.  All of the
 smelters have installed pollution control equipment to reduce emissions into
 the ambient air, for example, electrostatic precipitators to remove particu-
 lates from dust-laden air out of roasters, dryers, reverberatory furnaces, and
 converters; and many of the smelters have acid plants to reduce S02 emissions
 primarily from converters.  Even with these emission controls, it is estimated
 that  52,000 tons/yr of particulates, an indeterminate amount of fumes that
 contain  noncondensables, and 3.5 million tons/yr of S02 are still emitted into
 the air  through the stack.  (This is based on 1974 reports and does not con-
 sider new modifications to the smelters since then.)  Sulfur dioxide quanti-
 ties are especially high because SOX from multiple-hearth roasters and rever-
 beratory furnaces is dilute, and only a portion is sent to acid plants and the
 larger portion is emitted without control.  Sulfur dioxide from converters can
 be  sent  to acid plants only when the converters are in the blowing operation
 since the 502 concentration is high.  The emissions discussed so far are
 called primary emissions because they are either sent to control equipment or
 are at least ducted to a stack for dispersion into the ambient air.

     Emissions of concern in this paper are secondary or fugitive emissions.
These fugitive emissions are those that escape through leaks in dryers,
 roasters, smelting furnaces, converters, and anode furnaces or escape from
 primary  hooding systems not designed with great enough capture velocity, or
 they escape because of the position of the process equipment in certain
 phases of operation.   Particulate fugitive emissions may be high around
multiple-hearth roasters where concentrate is being handled and roasted, old
 reverberatory furnaces, leaky waste heat boilers, and converters when the
 converter is not in stack or in-line with the main hood position.  Sulfur
dioxide fugitive emissions can be considerable from roasters, smelting fur-
naces, and converters.   Various reports state that 2 to 25 percent of the SO?
generated by the copper industry is fugitive emissions.  The amount of fugi-
tives varies considerably within a plant from day to day and hour to hour.

     Fugitive emissions are a problem at all  smelters, however, and in some
plant configurations  they are a difficult problem to handle efficiently.  The
following is a  summary of the copper smelters and their process equipment:


                                    -316-

-------
                                   No.  of  plants    No.  of  units
Copper smelters
     Green feed
     Multiple-hearth roaster
     Rotary dryer

     Fluid bed roaster
     Reverberatory furnace
     Electric furnace
     Flash furnace
     Noranda furnace
     Peirce-Smith converter
     Hoboken converter
     Anode furnace
     Fire refining furnace
     Acid plant
     Liquid S0£
     Dryer or roaster gas to
       acid plant
     Furnace gas to acid plant
     Converter gas to acid plant
     Total concentrate feed rate
       of 16 plants, tons/day
     Total copper production at
       16 plants, tons/day
16
 5
 4
 7

 4
11
 3
 1
 1
15
 1
12
 1
13
 3

 4
 6
13
             50
(includes dryers at concentrator
  plants)
             25
              3
             63
              5
             28

             20
              4
            -20,000

            *  5,700
     This paper will briefly describe the smelter operations, address the
effectiveness and costs of fugitive emission controls, and also discuss some
ideas on possible future plant designs to reduce fugitive emissions.
                                      -317-

-------
                                  INTRODUCTION


      Copper  produced  by  the  domestic  primary copper  industry is mainly from
 sulfide  ores comprised of  a  variety of minerals. Small amounts of copper ore
 also  are recovered  from  oxide ores, low-grade waste, and  imported ores.
 Because  most of  the domestic ore  is mined  in the southwestern states, the
 majority of  the  plants are located in that area1.  Figure  1 shows the locations
 of the 16 primary copper smelters in  the United States.   Because most copper
 ores  are sulfides,  copper  recovery processes have been developed to treat
 these ores.   These  processes recover  copper while removing most of the impuri-
 ties  present in  copper ore.  Remaining impurities are removed by refining.

      Copper  metal primarily  is recovered from copper ores by pyrometallurgical
 processing with  the remainder consisting of hydrometallurgical processes.  The
 pyrometallurgical processes  convert ore concentrate  into  an impure copper
 called blister copper.   The  processes consist of roasting or drying, smelting,
 converting,  and  refining.  The anode copper product  (as high as 99.8 percent
 copper)  is then  sent  to  a  refinery for final purification.

      Figure  2 represents a general flow sheet of the copper industry in the
 United States.   The figure shows the pyrometallurgical steps and the refining
 processes.

      This paper  deals with the state-of-the-art in the control of fugitive
 emissions created in  the smelting and converting departments, which will  be
 discussed in the following paragraphs.  Before beginning  a more detailed
 discussion of the smelting process, the following brief description of the
 traditional  and  still  most commonly used smelter operations will be presented.

      Ore concentrate,  containing about 25 percent copper, is usually railed to
 the smelter  and  stored.  From the storage area, the ore is generally conveyed
 to a  dryer,  then to subsequent operations, or to hoppers above a bank of
 multiple-hearth  roasters.  Feed from the hoppers is discharged on the top
 hearth of a  roaster where rotating arms push the concentrate to the center of
 the hearth where it cascades to the hearth below.  From this hearth, the
 concentrate  is directed  to the periphery where it cascades to the next hearth
 and then is  directed  through several  additional hearths.  The multiple-hearths
 are gas- or  oil-fired.   This roasting process dries the concentrate and
 removes  some of the sulfur in the ore so as to improve the matte grade in the
 following operation.  (Since burning of sulfur is exothermic, the temperature
 in all of the hearths  can be maintained at adequate temperatures with supple-
mental heating as required.)

     The dried or partially  roasted (calcined) ore concentrate is usually
transferred  from the  roasters in larry cars to a reverberatory furnace(s).

                                    -318-

-------
Figure 1.   Locations of primary copper smelters in the United States.

-------








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-------
The concentrate is charged into the reverb(s)  through pipes and/or hoppers
located at the top or along the side walls of  the reverb.   The concentrate
melts by reverberatory heating.  The melt with the addition of a silica flux-
ing agent forms a copper-bearing matte layer and a waste slag layer.  The
matte is tapped near the bottom of the reverb.  The lighter slag is tapped  at
a higher elevation than the matte.  The slag is collected in a slag pot or
ladle and carted to, and dumped at, a disposal area.  The ladle, in which the
matte is collected, is usually transferred by crane to a Peirce-Smith con-
verter (horizontal cylindrical furnace).  This furnace converts the matte into
blister copper and slag by means of air blown into the converter below the top
of the bath line.  The reaction is exothermic.  The slag, containing recover-
able copper, is poured from the mouth of the converter into a ladle, and the
slag is then returned to the reverb furnace.  After final blowing, the blister
copper (about 98 to 99 percent copper) is poured into a ladle and then trans-
ferred to an anode furnace.  This furnace is usually fired with natural gas
and completes the smelter refinement of copper  (99.5+ percent copper).  The
anode copper is poured from the furnace into molds or a continuous casting
wheel.

     These anodes, varying from 460 to 1000 Ib  are cooled  by  quenching and
then stored and/or loaded onto rail cars  for  delivery to a  refinery.   Figure  2
shows other alternatives to the traditional method of copper  smelting.
                                     -321-

-------
 A.   COPPER SMELTING FURNACES

      1.    The Smelting Process.   Copper smelting is the process  of  heating  a
 roasted  or dried sulfide ore concentrate to its melting point to separate much
 of the iron and undesirable impurities from the copper sulfides  and other
 valuable metals.  In the smelting furnace,  hot roasted calcines  or  raw  (green)
 concentrates are melted with siliceous and/or limestone flux,  as well as
 materials with recoverable copper values such as converter  slag, flue dusts,
 oxide ores, and copper scrap.  As the temperature in the furnace increases, a
 complex  series of reactions takes place and the charge separates into frac-
 tions.   The sulfur in the charge combines preferentially with  copper to form
 stable copper sulfides, which  are mutually  soluble with the molten  copper
 metal.   This fraction,  known as  matte,  typically contains from 20 to 45 per-
 cent copper (using the reverberatory practice)  as well  as other  impurities
 such as  sulfur, antimony, arsenic, iron, and precious  metals.  Since copper
 has a weak chemical  affinity for oxygen, very little copper oxide forms.  Iron
 combines preferentially with oxygen  to form iron oxides, which in turn react
 with the flux to form iron silicates.   These compounds  and  any calcium, mag-
 nesium,  and aluminum minerals  that were present in the  charge  form  a slag of
 lower specific gravity that is insoluble in the matte  and floats on top of  it.
 Any sulfur left over from the matte- and slag-forming  reactions  reacts with
 additional  oxygen  to form SOX gas (primarily S02,  some  S03), which  mixes with
 the combustion off-gases.   The energy necessary for smelting can be provided
 by  fossil  fuel  combustion,  electrical  power,  and partially  by  heat  of reaction
 from the oxidation of iron  sulfide to  iron  oxide.

      a.    The Reverberatory Furnace.   The workhorse of  the  U.S.  copper indus-
 try is the reverberatory furnace  or  reverb  (Figure 3),  which was  first in-
 troduced in  1879 and is  still used in modified  form at  11 of the  16  domestic
 smelters.   The  modern  reverb is an arch-roofed  or  suspended-roof horizontal
 chamber,  generally about 35 m in  length  and  10  m in  width.  Heat  is  supplied
 by  fossil-fuel-fired burners located  at  one  end  of the  furnace.  A reverbera-
 tory furnace  operates on  the basis of  the heat  from the  flame  radiating from
 the roof onto the  charge.   Thermal efficiency of the reverb is low.   However,
 the reverb  is  flexible with respect  to concentrate  composition and  is capable
 of  accepting  as  much as  1800 metric  tons of material per  day.

     Although  specific methods may vary  considerably, reverbs are generally
 charged  either  through the  furnace top or along  the  top  portion of the side
 walls.   Belt  slingers  (high speed  conveyors), hoppers, and Wagstaff guns
 (inclined chutes) may be used to  better  distribute  the charge over the molten
 bath.  Drag chains and screw conveyors have also been used for charging.
 Continuous charging  is not  practiced because of  the problem of creating local
 thermal  imbalances that could reduce the furnace temperature below the effici-
 ent  level needed for the smelting  reactions.  Slag  is drained periodically
 from skimming bays at one end of  the furnace and conveyed by short launders to
 slag pots.  The  slag can be cooled, solidified,  granulated,  or dumped molten.
Matte is  withdrawn periodically through  tap holes  in the  lower furnace wall.
The matte flows down launders and  into ladles, which are conveyed to the
converter by overhead cranes.
                                    -322-

-------
             A.   BALLOON FLUE
             B.   CONVERTER UPTAKE HOOD
             C.   ADDITIVE SYSTEM
             D.   MONITOR
             E.   E.O.T. CRANE  60/60
             F.   PEIRCE-SMITH  CONVERTER
             G.   LADLE
             H.   CONVERTER AISLE
             I.   REVERBERATORY FURNACE
             J.   WASTE HEAT BOILER
             K.   REVERB. FLUE
i
u>
NJ
                          Figure 3.  Typical  reverberatory  furnace  and  converter

               (Adapted from Kirk-Othmer Encyclopedia of Chemical Technology, Second Edition,
                Volume 6, page 148.)

-------
     The outlet gases from the reverb, which may run upward of 120,000 m /h,
usually contain between 0.2 percent and 1.5 percent S02-  The specific S02
content is dependent upon the sulfur content of the ore and whether or not the
concentrate was roasted prior to smelting.  Although there is considerable air
infiltration, the principal reason for the low-S02 content is the substantial
quantity of combustion air that must be provided to the furnace.  The outlet
gases contain vapors (i.e., water vapor and some sulfurous and sulfuric acid)
as well as considerable dust and fume, including trace metal compounds of
arsenic, antimony, lead, and zinc.  These gases are generally passed through
waste heat boilers to recover much of the heat of the combustion gas, and are
finally cleaned of particulate by means of hot electrostatic precipitators or
baghouses and vented to the atmosphere.

     b.   The Electric Furnace.  The electric copper smelting furnace (Figure
4) has traditionally been used in Scandinavian areas where hydroelectric power
is cheap and fossil fuels are expensive.  The first such furnace in the United
States started operation in 1972, and two more smelters have since adopted
this technology.  The electric furnace is rectangular in cross-section with a
firebrick sprung-arch roof.  The largest are about 35 m in length and 10 m in
width.  Carbon electrodes are placed in contact with the molten slag, and the
heat required for smelting is generated by electrical resistance of the slag
to the submerged arc between electrode pairs.  Electrical ratings vary up to
51,000 kVA.  The chemical  and physical changes that occur in the molten bath
are similar to those that occur in a reverb, although the thermal efficiency
of the electric furnace is much higher.

     The charge of concentrate and fluxes is delivered to the roof of the
furnace by drag conveyors and then fed to the molten bath through multiple-
feed spouts near the electrodes and/or between the electrodes and sidewalls.
As the charge materials melt, they settle into the bath and form additional
matte and slag.  Separate launders or chutes on the furnace end wall may be
used to charge converter slag and reverts.  Matte is tapped into ladles from
tap holes placed in the hearth area near one end wall.  Slag is skimmed from
tap hole(s) in the opposite end wall  and delivered by launder(s) into slag
pot(s), which are usually hauled to the dump by trucks.

     Although originally designed as an alternative to the use of expensive
fuels in the Scandinavian countries,  the electric furnace also facilitates air
pollution control.   Large amounts of combustion air are not required, re-
sulting in an outlet gas about an order of magnitude less than a reverb, but
containing the same quantity of sulfur oxide emissions.  S02 concentrations of
2 to 4 percent can be expected,  and particulate emissions should be less than
a reverb because of the lower gas volume and more uniform gas flow.  The
electric furnace off-gas at all  three domestic smelters is combined with other
high-S02 gas streams and used as feed to contact sulfuric acid plants.

     c.    The Flash Furnace.   A more recent development in copper metallurgy
is the continuous  flash furnace,  which is more efficient in terms of energy
consumption and also produces a  more easily controlled stream of flue gas than
the reverb or electric  furnaces.   Flash furnaces are of two types, the
Outokumpu Oy and the Inco,  which differ primarily in their use of either
preheated air or commercial-grade oxygen to sustain the smelting reaction.

                                     -324-

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                ELECTRIC
                 POWER
CONVERTER
  SLAG
 LAUNDER
CALCINE
 FEED
    MATTE
                                                           SLAG
          Figure 4.   Electric smelting furnace.
             CONCENTRATE
 PREHEATED
    AIR
            CONCENTRATE BURNER

            —-OIL
                                                     SLAG
                 SLAG  MATTE
          Figure 5.  Outokumpu flash  smelting furnace.
                               -325-

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The  flash  furnace  is  in widespread  use  throughout the world, although only one
is operating  in  this  country  (under license  from Outokumpu).

     The Outokumpu furnace  (Figure  5) combines the functions of roasting,
smelting,  and partial converting  in a single furnace with three sections--
reaction shaft,  settler, and  uptake shaft.   Dried ore concentrates are in-
jected continuously along with flux and preheated air into the reaction shaft
through concentrate burners.  Oil may also be injected into the shaft.  The
finely divided concentrate  burns  in a "flash" combustion as the particles fall
down through the shaft, and the heat released from the combustion of the oil
and  sulfur sustains the smelting  reaction.  The process is similar to the
combustion of pulverized coal.  The molten particles fall into the settler
part of the furnace and separate  into matte and slag layers.  The matte, which
contains 45 to 75 percent copper, is tapped  from the settler and transferred
to converters for further processing.   The slag, which contains too much
copper to  discard, is also  processed further.  The flash furnace in the U.S.
does not have the flexibility to  recover copper from converter slags, and as a
result these also require slag treatment facilities.  The furnace outlet gases
are withdrawn from the uptake shaft.  They contain 10 to 20 percent S02 and
considerable quantities of entrained molten or semimolten particulate matter.
The gas is cooled in a waste  heat boiler, cleaned of dust in an electrostatic
precipitator, and used for  sulfuric  acid production.  The Inco flash furnace
(Figure 6), which requires a  low-cost source of oxygen to be economically
competitive, produces gases containing  75 to 80 percent S02» ideally suited
for liquid S02 manufacture.

     d.    The Noranda Furnace.  A newer type of smelting furnace used in the
United States is the Noranda continuous furnace (Figure 7), in which roasting,
smelting,  and partial converting  reactions are combined in a vessel similar to
a lengthened Pe1rce-Sm1th converter.  One U.S. plant has started operating
Norandas within the past year.  The  reactor  is a horizontal cylindrical fur-
nace about 21 m long.  It is fired  from both end walls, and oxygen-enriched
air is blown into the matte layer through side-mounted tuyeres.  The furnace
can be rotated on its horizontal axis, bringing the tuyeres out of the bath
and stopping the smelting process.   The compact design facilitates process
control, and the domestic Noranda smelter is highly instrumented.  The Noranda
was originally developed as a one-step process that would eliminate the con-
verter, thus significantly reducing  capital costs and eliminating the need for
a crane aisle.  In both of its commercial applications to date, however, the
use of a converter has been retained to allow better trace element control,
increased  production, and longer reactor-lining life.

     Concentrate and fluxes are fed  to the Noranda by a slinger at one end
that spreads the feed over the molten bath.  The high-grade matte, which
typically  contains approximately 70  percent copper, is periodically tapped
from the side of the furnace and then transported by ladles to standard con-
verters where it is batch-treated to remove additional sulfur and iron prior
to fire refining.  Slag, which contains 6 to 8 percent copper, is periodically
tapped from the end of the vessel  opposite the slinger.  Slag is upgraded by
milling, producing a concentrate (which is returned to the reactor) and a
tailing (which is discarded).   The off-gases leave the Noranda furnace through
its mouth where they are captured by water-cooled hoods and ducted to a waste

                                     -326-

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         CHALCOPYRITE
    SAND   CONCENTRATE
  CONSTANT
WEIGHT FEEDERS
      OXYGEN-*

           OXYGEN
                                                 PYRRHOTITE, CHALCOPYRITE
                                                 CONCENTRATES, AND SAND
                         SLAG  MATTE
             Figure 6.   Inco flash smelting furnace.
 CONCENTRATES
 AND FLUX

                                    TAPHOLES
                                 COPPER
                                   or
                                 MATTE
                                 21.3m
                   Figure 7.  Noranda process reactor.
                                  -327-

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 heat  boiler.   The  gases  are  passed  through  cyclones  and  electrostatic precipi-
 tators  to  remove participate matter,  and  then  used as  feed to a sulfuric acid
 plant.  With  30 percent  oxygen  enrichment,  the off-gases to  the acid plant
 contain 6  to  7 percent S02-  The  S02  concentration will  be only about 4 per-
 cent  if oxygen enrichment  is not  used.

      2.    Fugitive Emissions -  Smelting Furnaces.  Fugitive  emissions are
 those that escape  from processes  because  of the nature of the operation in-
 volved  or  escape from primary control  systems  for various reasons (i.e., less
 than  100 percent efficiency; inadequate capture velocity).   The emissions of
 concern in the copper industry  consist of particulates,  trace metal fumes, and
 sulfur  dioxide (S02).  Some  fugitive  emissions  (fugitives) occur with all
 types of smelting  furnaces.  The  emissions  are  present at all charging and
 tapping locations,  as well as through leaks in  the furnaces  and auxiliary
 equipment.  During  the operation  of smelting furnaces, the amounts of fugitive
 emissions  will depend on:

      0     Charging  technique

      0     Furnace  design and age

      0     Amount of time required to  charge feed and converter slag

      0     Location  and efficiency of  any  existent secondary  hooding

      0     Furnace maintenance and operations.

 Fugitive emissions  will  be less variable  over time with  the continuous flash
 and Noranda furnaces than the reverb  or electric furnaces.  The release of
 materials  through cracks and leaks is most serious with  the reverb because of
 both  its increased  gas volume and the fact that these  furnaces are generally
 older and  in poorer repair than the other designs.  The  electric furnace
 presents the additional  problem of leakage from the furnace at the roof line
 around the electrodes, as well  as burning of the electrode paste in this area
 at the openings in  the band  containers.

     With  the Noranda furnace,  the primary hood cannot maintain a perfectly
 tight seal  with the reactor during smelting, and some fugitive emissions will
 be released.   There will  also be dilute gases discharged through the mouth
when the furnace is rotated out from under the hooding system, even though the
 smelting reactions will  have largely stopped.

     A final  fugitives source near all smelting furnaces is the ladle, which
 is used to  transport the  molten matte to the converter aisle.

 B.   COPPER CONVERTERS

     1.    The Converting  Process.   Copper converting is the batch-type process
 by which blister copper  is produced from the copper/iron/sulfur matte formed
 in a smelting furnace.   It is essentially an adaptation of the Bessemer
 process developed by the  steel  industry.   Molten matte and silica flux are
charged to  the converter, and air or oxygen-enriched air is blown through
                                   -328-

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tuyeres into the melt to oxidize the iron  sulfides.   This  results  in  the
formation of an iron silicate slag,  which  floats  on  top of the  matte  and  can
be skimmed from the converter.  Further blowing oxidizes the copper sulfides
to blister copper, which is approximately  98 percent pure.  Remaining impuri-
ties can be removed by fire refining at the smelter  and electrolysis  at a
refinery.  The slag contains sufficient copper to be returned to the  smelting
furnace.  Almost all of the sulfur remaining in the  matte is removed  in the
converter, and the S02 content in the off-gas is  sufficiently high that many
smelters produce sulfuric acid from this feed stream.  However, sulfur re-
covery is complicated by the cyclic nature of the converting operation, which
results in major and frequent fluctuations in off-gas volumes and S02 con-
centrations.  Converting is exothermic and no fuel is needed to maintain  the
bath in a molten state.  In fact, smelter reverts, copper scrap, and, in  some
cases, copper concentrate may be charged to reduce its temperature and prevent
damage to the refractory lining.

     a.   The Peirce-Smith Converter.  The Peirce-Smith converter (Figure 8)
is a horizontal, refractory-lined, cylindrical furnace with an opening in the
horizontal side that serves as a mouth for charging feed materials and pouring
slag and blister copper.  It can rotate through an arc of about 120° from the
vertical for operational purposes.  Compressed air is supplied through a
horizontal row of tuyeres along its back.  The standard unit is about 4 m in
diameter and 9 m in length.  First developed in 1909, the Peirce-Smith con-
verter  is now used at  15 of the 16 domestic copper smelters, with as many as
nine units installed at one plant.  Two or three  converters are generally
associated with each smelting furnace. The Peirce-Smith converter is a rela-
tively  efficient furnace whose  high air flows permit  both large copper through-
puts and the charging  of bulky materials  and copper  scrap.

     With the converter rotated partly forward, molten  matte that has  been
transported from  the smelting furnace  by  the overhead crane  is  charged through
the converter mouth.   The compressed air  blast is put on, then  the converted
returned to its operating position.  Silica  flux  can  be added  either  before or
after  the converter is rotated  to the  upright  position.   The initial  blow is
for the formation  of slag during which  the iron  sulfides  in  the matte  are
preferentially  oxidized and  sulfur  is  removed  as  SOz  with the  off-gas.
Periodically,  slag  is  skimmed from  the  converter  and  fresh  matte  and  scrap are
added.   Blowing is  discontinued during  the skimming  operation.  The  process is
continued until  a  sufficient quantity  of  copper  sulfide (white metal)  has
accumulated  in  the converter and the  iron has  been  removed  as  art iron silicate
 slag.   The  copper blow then begins, and it continues until  the white metal has
 oxidized,  forming mainly  S0£ and blister  copper.  Upon completion of the
 copper blow,  the blister  copper is  poured into ladles for transfer to anode
 furnace(s).   A complete converter cycle lasts  about 10 to 12 hours for a 40
 percent matte grade.

      The outlet gases  from the  Peirce-Smith are  released through the same
 mouth used  for charging and pouring.   When the converter is in its upright
 operating position, the gases are drawn into a fixed hooding system  situated
 above the converter.   The hood  has a retractable gate that can be lowered to
 reduce leakage, and the off-take is controlled by regulation of the  draft on
 the flue system.  By stolchiometric calculation, the S02 content in  the con-
 verter off-gas can be as high as 20 percent.  However, the actual S02

                                     -329-

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               (end v«w)
(side view)
CO
O
I
        (1) Shell; (2) Hood; (3) Air baffle; (4) Stack fluxing belt and chute;  (5) Radiation
        pyrometer; (6) Converter mouth; (7) Turning mechanism; (8) Turning motor and speed
        reducer; (9) Rollers; (10) Turning rungs;  (11) Air-supply duct; (12)  Air-distribution
        ducts; (13) Automatic mechanical tuyere; (14) Tuyere; (15) Puncher protection  shields.
                                Figure 8.  Peirce-Smlth converter.

          (Adapted from Kirk-Othmer Encyclopedia of Chemical  Technology,  Second Edition
           volume 6.)

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concentration is in the range of 2 to 10 percent primarily  because  of  excess
air infiltration into the hood,  which cannot be physically  tight with  the
converter.   Oxygen enrichment of the compressed blast  air can  be used  to
partially reduce the dilution effect of this air infiltration.  Although a
reduction in S02 content is not  desirable,  the  dilution  air does serve to cool
the hot gases somewhat, which is necessary  to prevent  damage to downstream  gas
cleaning equipment such as electrostatic precipitators or baghouses.   Waste
heat boilers are also often employed on the converter  gas.   The cleaned gas is
used for acid production at most smelters;  however,  three domestic  plants
release it without specific S02  control. To minimize  the fluctuations in gas
flow and S02 content that occur  throughout  the  operating cycle, and ensure  a
relatively steady feed to the acid plant, the operation  of  two or more con-
verters must be properly scheduled to ensure that one  furnace  is always
charged with matte and blowing.

     b.   The Hoboken Converter.  The Hoboken converter  (Figure 9)  is  an
alternative to the Peirce-Smith  that was designed to largely eliminate the
problem of excess air infiltration into the flue gas off-take  system.   First
developed in the early 1930's in Belgium, a Hoboken has  been operated  at  a
single domestic primary smelter  for about 4 years; it is also  installed in  a
number of foreign copper plants.  The design of the furnace itself is  similar
to the Peirce-Smith.  However, instead of withdrawing the  off-gas  through the
converter mouth into a hood, the Hoboken is equipped with  an integral  side
flue located at one end of the furnace.  Shaped like an inverted  "U,"  this
flue, or siphon, rotates with the converter, as does the cylindrical duct to
which it is connected.  A counterweight balances the siphon.  The  cylindrical
duct is connected by an airtight joint to a fixed vertical  duct that leads  to
the gas cleaning system.  The Hoboken thus  provides a direct link at all  times
between the converter and the gas off-take, irrespective of its operating
position.

     2.   Fugitive Emissions - Converters.   Fugitive emissions from converters
are always present during charging and tapping, and during slag and copper
blowing.  Fugitives also occur during the rolling in and out of the converter
with blast air on.  During the operation of a Peirce-Smith converter  (10 to 12
hours to produce blister copper), the fugitive emissions that occur are depen-
dent on:

     0    Matte grade  - affects blowing time

     0    Charging technique

     0    Equipment design

     0    Material additions of anode  slag,  cold  material  (i.e., skulls,
          clean.ings,  etc.) and  flux.

     The Peirce-Smith  converter is  a principal  source of fugitive  emissions  in
a  copper smelter.  Basically, the furnace  operates  under a negative draft,  but
due  to  the  clearance  required between  the  mouth  of  the  converter and  main
hood/gate,  ambient air infiltrates  into the main  hood.  This  infiltration
disrupts the  flow  and causes  some of the discharge  gases from the  converter to


                                     -331-

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Figure 9.  Hoboken converter.
               -332-

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escape through this opening.   Fugitives  increase  significantly  during  the
times in the operating cycle  when compressed  air  is  blown  through  the  tuyeres.
Substantial  fugitive emissions also occur during  charging  and pouring  opera-
tions when the converter is rolled out and the hood  is no  longer positioned
above its mouth.

     The Hoboken converter's  operating cycle  and  charging  and pouring  opera-
tions are similar to the Peirce-Smith.  The principal  difference  is that the
link to the gas cleaning system is never broken,  as  is the case when the
Peirce-Smith rotates forward  from under its hood.  With this in mind,  no
fugitive emissions theoretically should escape the Hoboken.  In actual prac-
tice, under good controlled operations, the Hoboken  can eliminate fugitives.
A constant zero or slightly negative draft can be maintained;  thus minimizing
fugitive emissions at the converter mouth.  Maintenance of the  proper draft is
complex.  If excessive fan draft occurs, this will cause entrainment of the
material in the molten bath,  which carries over into the siphon system and
forms accretions that restrict the gas flow and would disrupt the draft at the
mouth of the converter and would eventually cause emissions.

     Additional sources of fugitives common to both types of converters can be
leaks in the off-gas ductwork and  the ladles  that carry matte to  the  converter
and  ladles  that transport  blister  copper  to the anode furnaces.

C.   DISCUSSION OF  FUGITIVE EMISSION CONTROLS/PRACTICES

     1.   Smelting  Furnaces.  Methods to  decrease fugitive  emissions  around a
reverberatory  and  electric arc furnace could  include  the  following:

      0    Good, tight  fitting refractory/maintenance  of the furnace and  its
          auxiliaries  to  reduce  fugitive  emissions  through  leaks  in the  brick-
          work, and around electrodes and inspection  ports

      0    Hooding  over slag  and  matte launders to pick up fugitive emissions
          during  tapping  and  slagging operations

      0    Hooding  over slag  and  matte ladles  to  pick  up  fugitive  emissions
          during  tapping

      0     Having  adequate draft to maintain  furnace under slightly negative
           pressure

      The Noranda  furnace, although a smelting furnace,  is similar to the
 Peirce-Smith converter in design and operation.   Thus, fugitive  emissions can
 be treated in the same manner as a converter.

 D.   RELATIVE MERITS AND EFFICIENCIES OF DIFFERENT METHODS OF
      CONTROLLING FUGITIVE EMISSIONS - CONVERTERS

      Control of fugitive emissions in the vicinity of Peirce-Smith converters
 could reduce or nearly eliminate  these emissions and help  improve working
 conditions for smelter plant personnel.  Control can be achieved with varying
 degrees of success by the addition of fixed  or movable secondary  hoods or by


                                      -333-

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enclosure of the converter building.  Efficiency of fugitives control ranges
from 30 to 100 percent, depending upon hooding configurations as outlined in
Table 1.  Following are the major types of secondary hoods:

     0    Fixed type -- made of structural steel with an eliptical cross
          section.  It is attached to the primary or uptake hood.

     0    Fixed and movable -- consist of a movable intermediate hood and a
          hood fastened to the gate.  Both hoods are made of structural steel
          with eliptical cross sections so that they telescope in the re-
          tracted mode.

     0    Swing-away type with a fixed overhead hood — made of structural
          steel, refractory lined, and supported by pivot arms with a motor-
          ized drive to permit positioning during blowing and pouring opera-
          tions.

     0    Combination of fixed and movable and swing-away type.

     0    Controlled building evacuation with adequate number of air changes
          discharging to a fabric .filter (baghouse).

     The positions of the movable hoods for the various converter operations
are outlined in Table 1.

     Estimated fugitive emission control efficiencies are presented in Table
2.

     A descriptive summary of the secondary hooding systems is shown in Table
3.  This table points out some of the operational and maintenance problems
involved, and factors that affect control efficiency.

E.   COSTS OF FUGITIVE EMISSION CONTROL SYSTEMS

     1.    Cost Parameters - Secondary Hooding^.  This cost study includes
various items that must be installed or modified to achieve control of fugi-
tive emissions from the Peirce-Smith converter (this furnace being the worst
source of secondary emissions).  It does not include costs of certain opera-
ting procedures that would minimize fugitive emissions; e.g., allowing minimal
clearance between the primary uptake hood and the apron of the converter, or
maintaining proper matte charges to provide for direct flow of gases from the
mouth of the converter to the centerline of the primary uptake hood.

     The following items are considered in this cost study:

     0    A fixed hood having an elliptical cross section of 17 ft 6 in. on
          the major axis and 7 ft on the minor axis, and 9 ft 6 in. long.  The
          plate is 3/8-in.  carbon steel, with stiffeners of 7-in. channels.
          The fixed hood is bolted to the primary hood and to the smoke plenum
          of the secondary duct system.
                                    -334-

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                                          Table 1.  POSITIONS8 OF MOVABLE HOODS
i
U)
u>
Ul
Type
Movable
Gate hood
Swing- away
Matte
addition
Retracted
Retracted
Retracted
Blowing
or
holding
Extended
Extended
Retracted
or in oper-
ating posi-
tion
Skimming
Extended
Extended
Operating
position
Rabbling
Partially or
fully extended
Partially ex-
tended
Retracted
Collar
pulling
Retracted
Retracted
Retracted
Pouring
Extended
Extended
Operating
position
                 * Following are definitions of hood positions:


                   Retracted - hood is in its highest or extreme position away from  the
                               converter.


                   Extended  - the hood is in its lowest or operating  position.


                   Partially extended - hood is extended as far  as  practical  to maximize secondary
                               emissions control.

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I
CO
co
                                     Table  2.   PEDCo'S ESTIMATED HOODING EFFICIENCIES'

                                                   (Values In  percent)
Hood type
Fixed
Fixed and movable
Fixed and swing-away
Fixed, movable, and swing-away
Enclosed building
Matte
or
hot metal
addition
30-50
30-50
30-50
30-50
95b-100
niister
or
hot metal
pouring
30-50
40-70
80-90
BO-90
95b-100
Skimming
or
rabbling
30-50
40-70
50-70°
60-«0C
95b-100
Blowing
60-70
70-90
80-90
80-90
95b-100
                   Host system efficiencies would be higher if air motion* (i.e.,  open  doors, man-cooling
                   fans, monitors,  etc.) could be eliminated.   Skimming in removal of slag  from the con-
                   verter by tilting of the converter.   Rabbling is removal of slag from the converter by
                   tilting of the converter and manual use of a rake to work the molten bath.
                   Reduced efficiency due to air motions; if doors are  left open this efficiency  could drop to 50%.

                 c Efficiency during skimming would be similar to blister pouring.

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                                        Table  3.   SUMMARY  OF  CURRENT  FUGITIVE  EMISSION CONTROL  SYSTEMS
                         Type
                      Monitor. Natural
                      U.S.
                     Monitor, puwered
 I
U>
OJ
Fixed hood with
secondary emission
ducting - U.S.
                     Enclosed converter
                     hood-swing away type
                     with fixed hood
                     Enclosed  building
                         Design and operation
                         Simple design.   Relies  on outside
                         »1r moven«nt for removal of emis-
                         sions from the  area.
                         Sirple design.   Large air move-
                         ment required at the fans.  Re-
                         moval  rate is constant.
Clearance problems for crane hook
and cables during collar pulling or
matte additions.  Retrofit diffi-
culties for ducting, fans,  breech-
ing, and dust bins.   Operational at
ill tines that converters are on
line.   Good face and capture
velocities required.
                        Clearance problems for crane hook
                        and cables during collar pullino or
                        irstte additions (fixed hood).   Clear-
                        ance problem for floor space  re-
                        lationship tc the fixed hnod;  rugged
                        drive mechanism needed for swing-
                        away converter hood.
                                        Operational and maintenance problems
                                        Haze in  building during emissions; outside air  movement
                                        affects  time required to clear the area.   Crane oper-
                                        ator and rainter.ance personnel working above the con-
                                        verter may  be required to wear face aspirators.   Visi-
                                        ble emissions in the monitor area.  Maintenance  in the
                                        converter area, electric overhead traveling crane and
                                        roof trusses for removal  of the settled emiscions other
                                        than gases.
                                        Blind pockets or short-circuited flows could cause haze
                                        and  emission buildup in the roof line area.  Grant
                                        operator may require the use of a face aspirator at
                                        times.  Maintenance of fans and drives.   Visible emis-
                                        sions at each powered monitor.   Maintenance in the
                                        converter area, electric overhead traveling crane and
                                        roof trusses for removal  of settled emissions other
                                        than gases.
Operational  damage to  hood  by  swinging or uncontrolled
electric overhead  traveling crane action during matte
addition or  collar pulling.  Maintenance is less in the
converter area,  electric overhead traveling crane and
roof trusses due to particle buildup.
                        Requires careful consideration of
                        all openings (personnel,  t*-ock,
                        rail, materials) to minimize air
                        notion.  Roof monitor  must  handle
                        all ventilation air for workers.
                        emissions and in leakages.  In-
                        creases building costs because of
                        wind load design, tightness, and
                        close-fitting openings.
                                       Space occupied in the aisle  by the  swing-auay converter
                                       hood when adding matte,  rabtlini. or skimming could
                                       hamper crane movements.   Crane must deposit the ladles
                                       for pnuring or skinning  and  at the  completion of the
                                       operation nust await retraction of  the hood before en-
                                       gaging the ladle.   Maintenance of the swing-away
                                       mechanism and minimal  maintenance for removal  of par-
                                       ticulate buildup that  occurs during matte additions
                                       and rabbling.
                                       All openings must  be maintained constantly against ex-
                                       cessive air infiltration.  Tight siding and roofing
                                       required.   Air  circulation within tne building for
                                       the workers and process must te carefully controlled.
                                       Intoke and  exhaust fans reajfre preventive raintenance.
                                       Cleanup mainter.ar.ee for settled particulates in the
                                       converter area  is  similar to that for a monitored
                                       system, either  natural or powered.
                                                                                                                                                     Efficiency
                                                           Dependent  on outside air
                                                           currents and inside air
                                                           cation.
                                                           Dependent on number of
                                                           monitors, fan size, build-
                                                           ing  design above tne con-
                                                           verter proper; air motions.
Dependent on the distance
of th? niouth of the  fixed
hood from the emission
source; also on the  capture
and face velocity created
by the fan at the mouth of
the fixed hood.
                                                          Dependent on operational
                                                          cycle.  When pcjrir.j, blow-
                                                          ing or slocgir.; the emis-
                                                          sion ccntrol hould be cood;
                                                          when addino rcstte, or rab-
                                                          bling it wojld be similar
                                                          to the fixed hoed.  Air no-
                                                          tions influences efficiency
                                                          1n all operations.
                                                        |  Dependent on oulldinj
                                                          tightness, air ration con-
                                                          trol, monitor exr.aust capa-
                                                          oi 11 ties.

-------
     0    The movable hood in the retracted position is parked above the fixed
          hood.  It has an independent track system with a five-speed,  double-
          grooved hoist unit and slack cable limit switch.  The movable head
          is 9 ft long and is elliptical, with a major axis of 18 ft 6  in.  and
          minor axis of 7 ft 6 in.  These dimensions provide a 3-1/3-in.
          clearance between the movable and fixed hoods.  There are mating
          plates on the lower end of the fixed hood and on the top of the
          movable hood.  The lower end of the movable hood is fitted with a
          12-in. asbestos-type curtain that follows the elliptical perimeter
          to form a seal with the gate hood.  The movable hood is constructed
          of 3/8-in. carbon steel with stiffeners of 7-in. channels.

     0    The gate hood is elliptical  in cross section with a major axis of 16
          ft 6 in. and a minor axis of 6 ft 6 in.  It is 9 ft long.  Clearance
          between the fixed hood and the gate is thus 3-1/2 in.  The hood will
          be bolted to the gate. The plate is 3/8-in. carbon steel reinforced
          with 7-in. channels.

     The dimensions listed above would be modified for each converter layout
to provide the required clearances.  Design considerations may dictate  that
the fixed hood is the largest unit, with the movable hood under it and  the
gate hood under the movable hood.

     0    If crane runway rail height  is a problem, the smoke plenum of the
          secondary hooding duct system could be fitted in as shown. The
          plenum would span the primary uptake hood and would have a secondary
          hood dust bin affixed on each end.  The dust bins would be equipped
          with pneumatic dust valves and discharge pipes.  No provision is
          made in this study for removal of dust in the dust bins.  The smoke
          plenum for this cost study is 4 ft by 4 ft 8 in. by 21  ft. It is
          constructed of 3/8-in. steel  with 6-in. channel stiffeners.

     0    The secondary hooding duct system would have an uptake from each
          dust bin adjacent to the converter and then pass to its main  ducting
          header for fugitive emissions. The damper valve shown would be
          adjacent to the main ducting header and would be closed when  the
          converter is out of service.   Existing facilities would determine
          the path of retrofit.  The gases go to a dust bin ahead of the fans
          and from there to the breeching into the main converter gas duct  and
          to the stack (Figure 10).  For this study, the length of the  main
          duct runs is 600 ft.

     0    The fans considered in this  estimate are Buffalo Forge type 1320  BL,
          single inlet, arrangement 1,  class 3 with 145 bhp, 785 rpm, 80,000
          ft3/min at 200°F.  There would be one fan for each converter  in the
          plant; as many fans as are required would be tied into the system.

     0    Support items for the system include piping, wiring, foundations,
          supports for ducting every 20 ft, expansion joints, miscellaneous
          platforms, and walkways. Valves, fans, dust bins, and similar items
          are flanged for. ease of maintenance.
                                     -338-

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U)
LJ
SECONDARY
  HOOD
 DUCTING
                        DROP OUT
                        DUST BIN
                                                    BAGHOUSE
i-c


\ /
;


\ /
;


\ /
i "j ' N r ) /
j
/
                                                                       BUTTERFLY
                                                                         VALVE
                                                                                    MAIN
                                                                                  CONVERTER
                                                                                    GASES
                                                                                    DUCT
                 Figure 10.   Fugitive dust ducting  system  (with baghouse)
                                    from  converter building to  stack.

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     Estimates of total installed costs are based on current (1978) costs for
major components of specified sizes, as provided by equipment suppliers.
Estimates of fabrication costs and installation charges are based on general
accepted engineering practices.

     A 5 percent contingency factor to allow for emissions testing, equipment
changes, etc., is applied to the total of the direct and indirect costs.   An
escalation factor of 7-1/2 percent per year is used to account for increases
in cost of equipment, labor, and services before and during construction.
Direct capital costs include equipment, instrumentation, piping,  electrical,
structural, foundations, site work, insulation, and painting.  Indirect capi-
tal costs include the following:  engineering costs, contractor's fee and
expenses, interest (accrued during construction on borrowed capital-estimated
at 9 percent per year), freight, off-site expenditures, taxes (sales tax  of 4
percent of equipment cost), start-up or shake-down, and spares.

     Annualized costs include both operating costs and fixed capital charges
and consist of:  utilities; labor and fringe benefits, maintenance, plant
overhead, and total fixed costs (amounting to 19.97 percent of total installed
costs and consisting of depreciation over 15 years at 6.67 percent unless
otherwise indicated, property insurance at 0.3 percent, property  taxes at 4
percent, and interest on borrowed capital  at 9 percent).

     2.    Capital Costs.  Table 4 shows the direct cots, indirect costs
Including 1 year of contingency and escalation, and total  capital costs for
plants containing one to nine converters.

     3.    Operating Costs.   Operating costs include the following:   operating
labor at $8 per man-hour, supervision at 15 percent of labor, maintenance for
labor and supplies at 2 percent of total capital cost, maintenance materials
at 15 percent of maintenance labor and supplies, electricity at 35 mills/kWh,
plant overhead at 50 percent of operations, and payroll at 20 percent of the
operating labor costs.   The fixed costs include a straight-line 15 years
depreciation, 0.3 percent for insurance, 4 percent for taxes, and 9 percent
for capital costs.  Table 5 lists the operating costs for a multiconverter
plant.

     Additional handling of slag and blister ladles may cause delays in opera-
tion of the movable and swing-away converter hoods.  It is estimated that a
delay of 5 to 15 seconds may occur with each ladle movement, equivalent to a
total delay of 3 to 10 minutes per day or a 0.23 to 0.7 percent production
slowdown.  This loss is calculated on an annual basis as part of  the operating
cost since it is negligible in comparison with other delays that  are encoun-
tered such as delay because of lack of matte or because the anode furnace
cannot accept more blister copper or maintenance of converters or reverbera-
tory or electric arc furnace, etc.

     Each of these systems is connected to a main discharge duct  and an ex-
hauster type fan, which exhausts to a stack.

     Relative capital costs of hooding for a five-converter smelter increase
in the following order:  fixed, fixed with movable, fixed with swing-away,


                                     -340-

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Table 4.  ESTIMATED
        HOODING FOR
CAPITAL COSTS OF SECONDARY
MULTICONVERTER PLANT
                    (dollars)
No. of
converters
1
2
3
4
5
6
7
8
9
Direct
costs
760,000
1,216,000
1,532,000
1,771,000
2,211,000
3,219,000
3,601,000
3,880,000
4,402,000
Indirect
costs
532,000
785,000
963,000
1,255,000
1,463,000
2,122,000
2,383,000
2,545,000
2,850,000
Total
costs
1,292,000
2,001,000
2,495,000
3,026,000
3,674,000
5,341,000
5,984,000
6,425,000
7,252,000
                     -341-

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                      Table  5.   ESTIMATED ANNUAL  OPERATING  COSTS  FOR SECONDARY HOODING

                                           IN A MULTICONVERTER  PLANT
                                                   (dollars)
No. of
converters
1
2
3
4
5
6
7
8
9
Labor
supervision
10,000
21,000
31,000
41,000
51,000
62,000
72,000
82,000
93,000
Maintenance
labor, supplies,
and materials
30,000
46,000
57,000
70,000
85,000
124,000
138,000
148,000
167,000
Overhead
plant and
payroll
22,000
38,000
50,000
64,000
78,000
105,000
119,000
131,000
149,000
Utilities
1,000
3,000
4,000
5,000
6,000
8,000
9,000
10,000
11,000
Fixed
costs
258,000
400,000
498,000
604,000
734,000
1,077,000
1,195,000
1,283,000
1,448,000
Total
annual
costs
321,000
508,000
640,000
784,000
954,000
1,376,000
1,533,000
1,654,000
1,868,000
ro
I

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fixed with movable and swing-away,  and controlled  building  evacuation.   Fol-
lowing are estimated costs to retrofit a smelter with five  converters:

     Fixed - $2.98 million

     Fixed/swing-away - $3.04 million

     Fixed/movable - $3.39 million

     Fixed/movable/swing-away - $3.67 million

     Enclosed building - $5.14 million

The enclosed building with baghouse, fans, and ducting is estimated at $11.78
million.

     As shown in preceding tables, the costs of retrofitting fugitive emission
control systems are high.  The costs shown are for so-called "typical" smel-
ters.  Retrofit factors have been included in the costs and are estimated
based on  the "normal" problems encountered with retrofitting a converter shop
that was  not originally designed to have equipment installed.  Some existing
shops are so constricted  that retrofitting ductwork  that will not  interfere
with operations (i.e., crane, etc.) and is practically impossible.  No smelter
is really typical.  They  are all different and  have  different problems associ-
ated in retrofitting  the  equipment.  Therefore, it must be pointed out that
fugitive  emission control costs must be analyzed  on  a site-specific basis and
much thought given  to all related operations near a  hooding system before
retrofit  factors  are  assigned to a  given  plant.

F.   CURRENT AND  POSSIBLE FUTURE METHODS/PROCESSES FOR EMISSION CONTROL

     The  industry has remained the  same in technology and  design  since  1909
with  the  reverberatory furnace and  Peirce-Smith converter.  Some  methods  have
been  utilized and many methods could  possibly  be  adopted in order to  control
fugitive  emissions  in smelting and  converting  operations at a copper  smelter.
The  ideas discussed here  would  involve design  of  equipment new  to the copper
 industry, but not new to  other metallurgical  industries  (i.e.,  steel  indus-
 try).

      0     Charging floor technique

      0     Q-BOF type furnace

      0     Cascading system from calcined ore to matte to blister copper to
           anodes

      0     Covered ladles/stopper rods/autopour units

      0    Evacuated building with each furnace in its own enclosure
                                      -343-

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     The  following  opinions  have  been  formed with  respect to control of fugi-
 tive emissions  from personal observations of various copper smelters in the
 country:

     Roasters -  Nearly all of  the multihearth  roasters observed have observ-
 able particulate fugitive emissions and detectable st-Tfur dioxide emissions.
 As  far as  can be determined, these fugitive emissions have been greatly
 reduced by the  use  of fluid-bed roasters with  cyclone collectors.  These
 roasters appear  to  be operating with minimal problems.  Besides nearly elimi-
 nating fugitives due to leakage, the concentrate is fed in a slurry form to
 the fluid-bed roaster, thus minimizing the escape  of fugitives during con-
 centrate transport.  (Sulfur dioxide in the fluid-bed roaster gas stream,
 unlike multihearths, is rich enough to be sent to  an acid plant.  Thus, fluid-
 bed roasters, besides reducing fugitive emissions, also improve ambient air.)

     Smelting furnaces - The reverberatory furnaces (reverbs) observed usually
 had leaks  in the brickwork in which fugitive emissions could be seen.  Sulfur
 dioxide emissions can usually be detected, particularly when standing at a
 location even with  or above the reverb roof.

     The electric furnaces observed have had a minimal amount of fugitives
 around them.  The furnaces have had much tighter brickwork than the reverbs.
 At  one smelter,  no  fugitive emissions could be seen coming from the electric
 furnace.   At another smelter, only some emissions around the electrodes con-
 sisting of paste that was ignited at the furnace roof line could be seen.

     The Noranda  furnaces (reactors) observed  showed no fugitive leakage
 during the  smelting  period.

     Converting  furnaces - The most common converter is the Peirce-Smith.  All
 of  these converters  generate varying amounts of fugitive emissions, from
 minimal (barely  visible) to considerable (dense cloud) depending on the mode
 of  operations.   Some Peirce-Smith converters emit minimal amounts of fugitives
 during blowing operations because the hooding  system and the sliding gate form
 a close fit with  the mouth of the converter.   If wide gaps are present between
 the converter and the main hood and gate, or if leaks are present in the
 hooding system,  then fugitives are heavy and are very noticeable in the con-
 verter aisle during  blowing.  The main point,  however, is that fugitives can
 be minimal during slag or copper blowing if a converter has good hooding and
 good maintenance.  The problem with all Peirce-Smith converters observed
with respect to  fugitive emissions occurs when the converters are "out of
 stack," meaning  that the gate hood is up and the converter mouth is rotated
out from under the hood (i.e., receiving a charge or is pouring slag or
 blister copper,  etc.).   When a converter containing matte is rolled out, air
 is blown through the tuyeres (which are approximately 8 in.  below the bath
 level  during blowing) for a short time to prevent plugging as the tuyeres
emerge; also when the matte is added to the converter, air is blown through
the tuyers for a short time to prevent plugging.  Fugitive emissions are
usually great during this period.   Fugitives continue to escape the main
hooding system even when the blow air has stopped, but in lesser amounts.
Secondary hooding can help capture some of these fugitive emissions.  In
summary,  fugitive emissions from Peirce-Smith converters can be controlled
                                    -344-

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effectively when they are in the blowing mode by means of tight hoods.   When
out of stack, however, only a portion of the fugitives from a Peirce-Smith  can
be controlled by secondary hooding.   One smelter has a modified enclosed
converter building in which 60 percent of the roof truss area is under  control
of a fugitive exhaust system to a baghouse.   This system will not be commented
on because it still is being modified and is not a totally enclosed and con-
trolled evacuation type.

     Escape of fugitive emissions could be minimal from the Peirce-Smith
converter if it could be charged from a ground-operated machine (discussed
later) rather than by an overhead-type crane.  Secondary hooding would  be
effective if it could be kept in position directly over the fugitive sources.
Retrofitted secondary hoods, now at some smelters, must be positioned to be
clear of the crane operations for charging the converter, etc.  This makes
fugitive emission control at Peirce-Smith converters a difficult problem with
the current building design.

     Hoboken converters - It may not be fair to compare Hobokens and Peirce-
Smith converters (with secondary hooding) on an equal basis.  The Hoboken unit
is designed to operate with a zero or slight negative pressure.  The Hoboken-
Overpelt unit in Belgium operates with little or no emissions during blowing
operations.  Some fugitive emissions are released during tapping, slagging,
and charging operations at the ladle.  A telescopic secondary hood operating
in conjunction with a Hoboken converter would eliminate emissions during
slagging and tapping  blister copper and greatly reduce  the small amounts
of emissions during charging.

     A Peirce-Smith converter with retrofitted secondary hooding cannot really
be compared with new  equipment designed to eliminate  fugitive emissions.  A
better comparison would be the installation  of a  Peirce-Smith converter in a
new shop which would  be designed with hoods  specifically to  capture  fugitive
emissions.

     The Hoboken converter can control  fugitive emissions much  more  readily
than the Peirce-Smith type.

     Other observed equipment  currently  in  use  to control  fugitives  are as
follows:

     Hoods over matte and reverb slag  tapping holes can be  very effective.
Hoods  over a filling  slag pot  can also  control  emissions  to  the point  where
none  can  be  observed.  Swing-away hoods  that can  be lowered  over ladles
receiving matte can  be  effective.  The  hoods observed appear to pull most  of
the fugitives  effectively,  although  some escape the outer periphery of the
ladle  or  hood  because of the large clearance between the hood and the  top  of
the  ladle.

      Even newly designed shops installing secondary ductwork on a Peirce-Smith
converter that would minimize  fugitives and not be in the way of the overhead
cranes etc., create  many design problems.
                                     -345-

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     A possible answer to the Peirce-Smith fugitive emission problem would be
a charging floor technique.  A charging machine(s), illustrated in Figure 11,
could replace the overhead cranes that transport ladles of matte or slag.  A
charging machine, for example, could lift a ladle of matte, move back and
pivot around 180 degrees, then move to the converter.  The arms would lift the
ladle to the desired height and tilt the ladle for discharging the matte into
the converter.  The converter would be contained or encapsulated with a hood
to capture the fugitive emissions.  A portion of the hood for the converter
would be retractable during the times an overhead crane is used for main-
tenance.  A Hoboken converter without a main hood would be better than a
Peirce-Smith converter in this mode of operation.

     With the elimination of overhead cranes for production in the converting
aisle, the proper ducting could be installed above the ladle and mouth area.
The ducting could be located in positions most suitable for when the converter
would be in the rolled out position.  A charging machine would perform all of
the duties of overhead cranes, except for maintenance.

     Whether using overhead cranes or charging machines, the transport of open
ladles from a matte-producing furnace to a blister-producing furnace means
escape of emissions from the ladles.  Fugitive emissions during ladle trans-
port are not a major source, but they do add to the fugitives problem.  Because
the ladles are often near the converter aisle floor, the fugitives that are
generated are near the operations people.  A possible method of reducing these
"ladle" emissions would be to have covers on the ladles that could be placed
on or taken off with a minimum amount of time and trouble.  (This may be
difficult in existing shops.)  In conjunction with covers, specially designed
bottom-pour ladles with stopper rods (Figure 12} could possibly be used at
smelters for molten metal transport.  Such a ladle with an autopour unit is
used in the steel industry where it is attached to the operation of the stopper
rod mechanism (Figure 12).  This would allow the crane operator to control the
flow of matte directly into a converter or blister copper into an anode fur-
nace.  A bottom-pour ladle could even be seated on a ladle support, and the
ladle tapped to a specially designed opening in the end of a converter through
a refractory-lined air tight joint/cover.  (In this latter case, the mouth of
the converter could be made smaller, if so desired, and would be used solely
for pouring and not receiving hot metal charge.)

     The electric overhead traveling crane (EOT) could be adapted to minimize
fugitive emissions from ladles in transport, ladles being filled, or ladles
pouring molten metal into a converter or anode furnace, by using a capture
hood fixed to the spreader beam (Figure 13).  The capture hood would be fixed
to a sectionalized telescopic column (similar to that used in the steel indus-
try for handling ingots going to and returning from a soaking pit).  The
telescopic column would be attached to the trolley, where a transfer duct
would discharge to a fixed split rubber covered duct fixed to the EOT's girder.
This duct would discharge to another split rubber covered duct adjacent to the'
building columns on the crane runway at the walkway level or at the roof truss
line.  This second duct would discharge to a baghouse.  An I.D. fan, posi-
tioned on the trolley, walkway, or girder, would supply the required capture
velocity.  Another technique would be to discharge from the trolley to the
roof truss and use the building monitor for discharging to a baghouse.


                                     -346-

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I
to
                                   MODIFIED
                                   CHARGING
                                   MACHINE
                                            Figure 11.  Modified charging machine.

-------
Figure 12.   Hydraulic cylinder mounted on  barrel  of ladle rigging  raises
  and lowers stopper rod to control  flow of molten steel  from  ladle to
                               ingot mold.
                                   -348-

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Figure 13.   Sketch of E.O.T.  crane with capture hood.
                        -349-

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     Another fugitive-emission control scheme could be an evacuated building
with each furnace in its own enclosure with an independent pendant-operated
crane for handling ladles, etc., within the enclosure.  Ladles would be removed
or brought into the enclosure through a movable rail-mounted car that would
pass through a sliding door.  Emissions would be exhausted through a duct
system to a central point.

     In summary, as far as fugitive emission control is concerned, there are
methods currently used that are reducing fugitives, but many ideas need to be
developed and good ideas tested so that fugitive emissions can be eliminated
in a feasible manner.  Elimination of fugitives would improve working condi-
tions in a smelter.  Besides that, new ideas and equipment that have been
implemented in industry to solve a problem have often lead to a technical
breakthrough that was not originally foreseen.
                                   -350-

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            APPENDIX A
Figure A-l,  Matte  charging operation.
                 -351-

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Figure A-2.  Peirce-Smith converter - retracted



           hooding, pictorial view.




                    -352-

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              T.O.  RAIL
               SMOKE
               HOOD
               PLENUM
                                  TO SECONDARY
                                     HOODING
                                    MAIN DUCT
Figure A-3.   Secondary  converter hood configuration
                         -353-

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                                                     .JICOHMIT WCT
                                                    /CUM lid
Figure A-4.   Fixed, movable and  gate hoods  - front view.
                          -354-

-------
                                                     TO CttMM WWi>
                                                      wr*
                                                  SUMMIT MCI
                                                INSTALL LIMIT SWITCH TO
                                                TRAVEL OF TROLLY FOR
                                                CHARGING OR COLLAR PULLING
                                                TO PROTECT HOODING: FOR
                                                OTHER MAINT. WORK, ETC.
                                                REQUIRING THE HOOK TO WORK
                                                IN THIS AREA THE LIMIT
                                                SWITCH WILL ENERGIZE A GONG
                                                ft FLASHING LIGHT TO ALERT
                                                THE CRANEMAN t CONVERTER
                                                OPERATORS THAT THE LOAD ON
                                                THE CRANE OR HOOK CAN
                                                INTERFERE OR DAMAGE THE
                                                HOOD UNLESS THE HOODING
                                                IS RETRACTED.
                                                TUt MM
Figure A-5.   Peirce-Smith converter -  side view,

  blister pouring  operation,  hooding extended.
                           -355-

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                                               CSMW.
             (UCATIOH VVt> It
             « Itt CWUIt MMUkl)
                                                  TO inwt,!i mini
                                                    !U (»ll
                                               ULOWM.T MCI »
                                                                wtunt
                                                         NP09 MOIST ICCMUia
                                                        "•>,.,
                                             111 M TW ma
Figure  A-6.
Peirce-Smith converter
 hooding in position.
-  side  view,
                       -356-

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   Photo A:  Morenci - converter with gate (upper left)  and
   apron (center left), converter operating platform (lower
   right), and typical ladle with lifting bale (lower left).
Photo B:   Morenci  - fixed hood,  smoke  plenum  and  duct  (upper
center and left),  and gate (lower left).
                             -357-

-------
Photo C:  Morenci - fixed hood, smoke plenum and duct to dust
bin (upper right, upper and middle center), and gate (center
and lower right).
Photo D:  Morenci - view of converter uptakes, fixed hood,
smoke plenum, dust and gates.
                        -358-

-------
Photo E:   Morenci - view of converter aisle.   Converters to
the left and reverberatory furnaces are on the right.
      r:  Morenci - view of secondary hood ducting (center
left to center right).

-------
Photo G:   Morenci - view of secondary hood ducting leading to
thp ctarlc
Photo H:  Ajo - ladle (center) pouring matte into the con-
verter by means of the overhead crane.  Gate in raised
position (upper center).   Apron on converter is seen clearly.
                            -360-

-------
 Photo I:  Ajo - secondary emissions (at center) are visible
 with the gate in a raised position (center) and fixed hood
 (upper center).
Photo J:  Ajo - secondary emissions (at center) are visible
with the gate in a raised position (upper center), the fixed
hood, smoke plenum and dust bin (upper center and left)
                            -361-

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                                 REFERENCES
1.  Environmental Assessment of the Domestic Primary Copper, Lead, and Zinc
    Industries (prepublication copy).  PEDCo Environmental, Inc.  EPA Con-
    tract No. 68-03-2537, Work Directive No. 1.  October 1978.

2.  Background Information for New Source Performance Standards:  Primary
    Copper, Lead, and Zinc Smelters.  EPA-450/2-74-002a.  October 1974.

3.  S02 Control for the Primary Copper Smelter Reverberatory Furnace (Draft),
    Pacific Environmental Services, Inc.  EPA Contract No.  68-03-2398.
    August 1977.

4.  Copper - State-of-the-Art.  Donald G. Treilhard.  Engineering/Mining
    Journal.  April 1973.

5.  Flash Smelting - A World Beating Finnish Process.  World Mining.  March
    1978.

6.  Kennecott Plans Mid-year Smelter Startup.  Mining Engineering.  May 1978.

7.  The Hoboken Copper Converter.   Mechanism, Metallurgie Hoboken-Oberpelt.

8.  Secondary Hooding for Peirce-Smith Converters.   PEDCo Environmental, Inc.
    EPA Contract No. 68-02-1321,  Task No. 47.  December 1976.
                                  -362-

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Core Room Emissions in Foundries
        William D, Scott
   Southern Research Institute
         Birmingham, AL

      Robert C. Cummisford
       Krause Milling Co.
          Milwaukee, WI
    Presentation to Third EPA
 Symposium on Fugitive Emissions
       October 23-25, 1978
        San Francisco, CA
              -363-

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                                    ABSTRACT
Cores are the preformed sand inserts placed in foundry molds to produce the
internal cavities in the castings used by our society.  Traditionally the
sand used for coremaking has been bonded with drying oils that were thermally
set by the heat of electric, coke, oil or gas-fired ovens.  Thirty years ago
synthetic thermosetting resins, including furan and phenolic-based products,
were formulated for coremaking.  More recently other chemical binders, in-
cluding some that do not require baking, have been developed that give faster
cure times.  For the most part, technical developments in foundry binders
have been independent of environmental considerations.

It is estimated that the nation's foundries annually produce 3.3x106 pounds
of emissions during coremaking.  These emissions range from simple hydrocar-
bons such as methane through unsaturated aliphatics, various solvents, the
carbon oxides, and others most noted for their odors.  These emissions have
two basic sources:  The binder (and its subsequent polymerization reaction
products) and the oven emissions associated with fuel combustion.

Recent research has developed a new binder system based on a starch product
that satisfactorily bonds core sands which is inherently less prone to produce
objectionable emissions.  These low emissions levels have been demonstrated
in the laboratory.  The binder requires a drying step to develop maximum
strength.  Microwave energy has sucessfully been used with this system,
effectively eliminating oven emissions at the foundry.
                                    -364-

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                       CORE ROOM EMISSIONS IN FOUNDRIES
     The casting process is the basis of all manufacture involving metal.
In the casting process, molten metal is poured into a mold which contains
a cavity with the desired shape of the final product.  The metal solidifies
and cools in this configuration.  Foundry molds are typically made from sand
and have two mated parts:  the cope (the upper half) and drag (the lower half).
Sand molds are prepared by ramming or blowing sand around a pattern.  Binders
are added to the sand prior to molding so that the patterns may be withdrawn
to leave the desired mold cavity.  These binders may be as simple as the wet
day in green sand molds or as complex as organic resins.

     When the configuration of the casting requires  internal voids or hidden
cavities, it is most economical to cast them  in place.  Preformed sand  in-
serts, called cores, are used for this purpose.  A  core must be rigid and
self-supporting, and therefore the binding agent must give it more strength
than is usually provided by mold binders.  Traditionally, the sand is mixed
with a drying oil which polymerizes or cures,  to bond the sand when heated.

     Cores are prepared  in a core box, such as  illustrated in Figure 1.  Cores
are often made with the  aid of mechanical equipment such  as  squeeze molders,
core blowers, or core  shooters, which  inject  the sand mixture quickly and
automatically into the core boxes.  The boxes are  stripped away from the sand
and the core  is laid on  a  flat or contoured support, called  a core drier,
which prevents deformation during the  oven baking  cycle.

     One of  the most significant  advances  in  foundry technology  in  the  last
thirty years  has been  the  development  of new  binders for  sand molds and cores.
These binders make  it  practical  to  design more complicated cores  and they
also allow  the  foundryman  to  achieve better dimensional accuracy  in the cast
product.  Table  I  lists  some  of  these  processes and the binders  employed.
The development  and description of  specific  binders for these processes have
recently been reviewed.  (1,2)*

      In general,  binder development has been directed toward the use of com-
 plex organic resins,  and the use of catalysts that allow curing without heat.
 Many of these "no-bake" binders were developed with no specific concern for
 their environmental impact.   However,  in current research and development
 of binders, more attention is being paid to reducing the level of emissions
 both in the mixing and curing, and during the pyrolysis of these binders.
 (3,4,5)   Inorganic systems based on phosphates and silicates have been touted
 as solutions to environmental problems in the foundry.(2)  Poor collapsibility
 of the cores has been reported, which makes core removal from the casting
 difficult and prevents their widespread use.(5,6)   The addition of organic
 additives to these systems to improve collapsibility produces pyrolysis pro-
 ducts of similar composition and magnitude to those from organic resins,  (7,8),
 but the molding and mixing emissions are low.
 * Numbers in parentheses refer to items in "References."

                                       -365-

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                     CAN BE METAL
                     OR PLASTIC
             CORE BOX
                                                     PATTERN
               CORE
                  MOLD
              MOLTEN METAL
CORE
 FLASK
                          POURING CUP

                            SPRUE
                                   COPE
DRAG
                                                FINISHED CASTING

                     Figure   1.  CASTING NOMENCLA TURE
                                    -366-

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process




Oil



Shell




Hot-Box




No-Bake  [Acid Cured]




No-Bake




Cold-Box




Spirit




Silicate
                                   TABLE I




                             Common Core Binders




                                        Binder
Drying oils



Phenolic Novalac Resins



Phenolic or Furan Resins



Phenolic or Furan Resins



Urethane Resins



Phenolic, Furan or Urethane Resins



Carbohydrates  (Starches)



Sodium  Silicate
                                       -367-

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     The widely accepted organic binders that require heat for curing — speci-
fically those for the shell, warm box, hot box and core oil processes - are
declining in usage as shown  in Figure 2.  (9)  Oil-sand mixtures must be heated
in a core oven.  These ovens may be heated by coal, oil, gas, or electricity.
Oven designs have been proposed which heat cores with hot exhaust gases from
metal melting furnaces.  Whatever the fuel, core ovens require extensive floor
space.  Vertical ovens which allow sufficient time at temperature (dwell time)
to cure the core binder are available which conserve floor space.

     Recently, core ovens have been developed which employ microwave energy
to cure the binder in a more controlled manner.  Design requirements are
radically different for this type of oven, in that wave reflection and shield-
ing rather than insulation and burner design are critical to the oven's ef-
ficiency. (10,11,12) These ovens are particulary effective in drying core
coatings.

Core Room Emissions

     There are two sources of emissions in the core room:  the emissions from
the core ovens and those released during the curing of the sand binders.

     The area where the cores are made is often separated from the remainder
of the foundry, sometimes even detached from the foundry building.  Core rooms
are ventilated to remove the chemical emissions, and particularly objectionable
odors, from the work area.  However, these emissions are usually exhausted
directly to the atmosphere outside the foundry, and may contribute signifi-
cantly to foundry fugitive emissions.

     Foundries using thermally-cured resins with core ovens can control in-
plant emissions if the ovens are properly vented, but unless they are equipped
with afterburners or scrubbers, pollutants will still be discharged to the
atmosphere outside the plant.   Such controls are rare.  Table II lists the
emissions expected during the mixing, molding, and curing of cores prepared
with thermal setting binders.

     Another approach has been to use "no-bake" binders, which require no
heat to cure, but may still release objectionable emissions as indicated in
Table III.

     Some core binder systems inherently release objectionable emissions during
curing.  Hexamethylamine (Hexa) is added to "shell" sand to provide formalde-
hyde to cure the phenolic resole resin, but it also introduces ammonia into
the atmosphere. (14,15)  The urethane-base cold-box process uses odorous ter-
tiary amines such as dimethylethylamine (DMEA) as a catylst, which must be
controlled with a phosphoric acid scrubber.  (16,17,18) Furan-phenol formalde-
hyde binders employing gaseous sulfur dioxide as a catalyst are also being
marketed as cold-box systems.  (19)  For both of these processes, the catalytic
gases must be contained and scrubbed to avoid contamination of the work area.
(18,19) These controls also are effective in reducing fugitive emissions or
these catalysts.

     As shown in Tables II and III, hydrocarbons are emitted during the curing
of the binders.  The most common hydrocarbon emissions are solvents, which
are added to the binders to lower the viscosity.  Some of these are aromatic


                                     -368-

-------
  300
  200 -
2
u.
o
                                                                           Cured No-Bike
                                                                           Box
                                                                   ^, podium Silicate


                                                                       •Alkyd Urathine
                     52  54  56  58  60
                                                                         Phenolic Uretlwm
48
70  72   74   76
  Figure 2.  A NNUAL BINDER CONSUMPTION (US).
                                        -369-

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                                TABLE II

     AIRBORNE EMISSIONS PROM CHEMICALLY BONDED THERMO-SETTING
     SYSTEMS DURING MIXING, MOLDING AND COREMAKING (13)
                                      CHEMICAL SPECIES

                                 /
/   f
                                                     /  /  /
CORE OIL
FURAN HOT-BOX
PHENOLIC HOT-BOX
SHELL
CARBOHYDRATE
7
7
7
7
7
0
7
X
X
7
0
0
0
7
0
0
0
0
X
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
?
0
7
7
0
7
7
7
7
0
7
7
7
7
0
0
?
?
0
0
0
7
7
0
7
ASUMES NORMAL VENTILATION, OPTIMIZED BINDER USAGE AND PROPER HANDLING
OF BINDER SYSTEM.
 0  NOT EXPECTED TO BE PRESENT IN SUFFICIENT QUANTITIES TO BE CONSIDERED
    A HEALTH HAZARD

 ?  POSSIBLY PRESENT IN WORKING ENVIRONMENT  DEPENDING UPON SPECIFIC
    FORMULATION AND SAND QUALITY

 X  PRESENT IN SUFFICIENT QUANTITIES TO BE CONSIDERED A POSSIBLE
    HEALTH HAZARD
                                -370-

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                                 TABLE III

          AIRBORNE EMISSIONS FROM CHEMICALLY BONDED
          "NO-BAKE" SYSTEMS DURING MIXING, MOLDING & COREMAKING (13)
                                         CHEMICAL SPECIES
                                                                 •*    *   /
FURAN NO-BAKE
(H3P04)
FURAN NO-BAKE
(ISA)
PHENOLIC NO-BAKE
(TSA)
ALKYD URETHANE
PHENOLIC URETHANE
SODIUM SILICATE
(C02 OR ESTER)
0


0
0
0
0
?
7

X
0
?
Q
0


0
0
0
0
0


0
0
0
0
0


0
?
?
0
0


0
0
0
0
0


?
0
0
0
0


?
0
0
0
?


X
0
?
0
0


?
0
0
0
0


?
0
?
0
?


0
0
0
0
0


?
0
0
0
ASSUMES NORMAL VENTILATION, OPTIMIZED BINDER USAGE AND PROPER HANDLING
OF BINDER SYSTEM


    0 NOT EXPECTED TO BE PRESENT IN SUFFICIENT QUANTITIES TO BE CONSIDERED
      A HEALTH HAZARD

    ? POSSIBLY PRESENT IN WORKING ENVIRONMENT - DEPENDING UPON SPECIFIC
      FORMULATION AND SAND QUALITY

    X PRESENT IN SUFFICIENT QUANTITIES TO BE CONSIDERED A POSSIBLE
      HEALTH HAZARD
                                     -371-

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compounds, which are readily released  into the atmosphere.  (1)  Thermally
cured binders are likely to give off methane and aliphatic hydrocarbons.
In core rooms with  inadequate ventilation, an oil mist is sometimes observed
in the area.  Some  CO may be produced  when curing thermal setting binders,
especially if coated sand is exposed to higher temperatures.   Traces of other
organic compounds in the core room atmosphere, such as amines, can be objec-
tionable because of their strong odor.  (20)

     The other source of core room emissions is the oven.  Depending upon
the oven type and configuration, there are combustion products from the fuel.
Natural gas or propane is preferred for a number of applications, including
the hot-box process and the shell process which was heated core boxes, because
the combustion/temperature is readily  controlled.  Drying ovens with natural
gas are also available, but with increasing industrial unavailability of this
fuel, more conversions are seen to either oil or coke.  In any case, conven-
tional oven emissions such as methane, carbon monoxide, carbon dioxide, and
water will be produced.  More complex  species may be formed, depending upon
oven efficiency.  Often all these combustion products are usually ventilated
directly to the outside.

       The use of electric heat essentially defers emission of these combus-
tion products to a  power plant, where  control may be better effected.  A com-
parison of oven emissions during core  baking between an electric oven and
a conventionally fired oven will define the proportions of the emissions due
to the combustion of the fuel and that produced by binder decomposition.

     During the work on organic binder decomposition emissions, a promising
new system based on carbohydrates was  identified.  It is marketed as a core
oil substitute and  expected to produce fewer emissions than the conventionally
used core oils since it is in a water  medium.  This binder is based upon the
controlled formation of starch polymers.  (21)

     The Spirit^ binder system is based on starch.  Starch is predominantly
otl-4 anhydro glucose polymer with some al-6 linkages.  This polymer is quite
large in its natural form.  In the Spirit system, starch is chemically treated
give a controlled distribution of lower molecular weights that are dispersible
in water.  Addition of aldehyde groups with at least two aldehyde groups on
each molecule completes the formulation.  At the time of use, an inorganic
salt catalyst is added.  This gives a  resin system that is basically carbohy-
drate.  Crosslinking is presumed to proceed through a reaction of the aldehydes
with alcohol groups present in the carbohydrate to form hemiacetal and then
acetal configuration.  Theoretically,  low temperature pyrolysis, such as
drying temperatures in the range of 120-150°C, should result in principally
water and carbon with possibly some small quantities of formaldehyde.
t registered Trade mark of Krause Milling Co., Milwaukee, WI


                                     -372-

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                            SPIRIT BINDER EMISSIONS

     Experiments were designed to evaluate the emissions during the baking
of cores bonded with the carbohydrate-based Spirit binder.  Cores were baked
in a conventional electric resistance oven and also in a microwave oven.
Table IV reports the results of these experiments.  Analysis of samples of
the gas taken in the oven cavity showed that the carbon monoxide content was
less than 25 ppm.  The total hydrocarbon concentration was approximately 25
ppm, but the aromatic portion, as reflected in the concentrations of benzene/
toluene, xylene, and naphthalene, was extremely low.  Trace amounts of formal-
dehyde were found.  As the binder contains no nitrogen in its formulation,
nitrogen-containing compounds were not expected nor analyzed for.  These
emissions are relatively low, approximately of the same order of magnitude
as for the sodium silicate process.

     It is anticipated that a foundry would be more satisfied with the shake-
out characteristics of the Spirt binder than with  sodium  silicate.  The general
surface finish of a gray iron automotive casting produced with  a Spirit bonded
core  (no mold wash) was equivalent to that of an oil-bonded core with a re-
fractory core wash, as illustrated in Figure 3.  (22)  Both of  these are com-
mercially acceptable.

     Shot blasting and grinding, which produce unhealthy  dust  emissions,  are
often  necessary  to remove adhering sand  from castings produced with  sodium
silicate; and  internal cores  such as  in  Figure 3 might  be difficult  to  produce
with  sodium  silicate  bonded  sand because  of  the problems  with  core removal.

Microwave Ovens

      As the  starch-based  binder must be  dried to  cure,  it is particularly
well  adapted to microwave curing.  The  literature contains  several references
 to this new application of  microwave energy.(12,21,23,24)  Essentially the
microwave  oven offers the foundryman a  controlled, emission-free oven that
 readily dries sand.   The  sand aggregate is only indirectly heated in the oven
 cavity, and therefore energy is not  wasted.   Currently the largest technical
 problem in the use of microwave ovens to produce foundry cores lies in the
 development of suitable materials for core boxes and drying racks.  Ideally,
 such materials should be readily formed, transparent to microwave energy,
 solvent-resistant, and resistant to temperatures up to approximately 300°C.
 (20,24) Many materials, including aluminum,  transite, and plastics of several
 types, have been tried, but at this time the optimum material has not been
 developed.  Once this problem has been overcome,  it  is anticipated that many
 foundries will consider conversion and subsequently may  reduce their core
 room emissions.

 Pouring Emissions

      Finally, it is  important  to note that the emissions from the core material
 during the pouring are only a  small part of the total pouring  emissions.  The
 core  is normally surrounded by metal, such that the  effective  sand-to-metal
 ratio  is very low and the pyrolysis of the core binder is nearly  complete.
 Table V shows the results of the evaluation of organic core materials  on


                                       -373-

-------
                           Table IV

                 Average Oven Emissions From
                Baking of Starch Bonded Molds
Carbon Monoxide
Total Hydrocarbons*

Benzene
Toluene
M-Xylene
O-Xylene
Naphthalene

Formaldehyde   .
Total Aldehydes*

Propanol        +
Ethanol/Methanol
                       Microwave Oven
                                (ppm)
 0.05
 0.01
 0.08
<0.01
<0.01

 1.04
<0.5

 0.05
 0.31
<25
 35

(0.02)
(<0.0
(0.02)
(0.8)
(0.02)
(0.23)
 Electric Re-
 sistance Oven
         (ppm)

        <25
         18

 0.05   (0.02)
 0.09   (0.02)
 0.09   (0.02)
<0.01
<0.01

 0.60
 1.5

 0.11
 0.18
(0.5)
(0.04)
(0.14)
* As methane
f As acetaldehyde
+ As ethanol
                                  -374-

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Figure  3.  COMPARATIVE CASTINGS. Core for casting on left made with
          Spirit binder; Core on right made with core oil.
                                   -375-

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                                                  Table V




                                                  Results


                                            Green Sand - Cored
                                                                                 Max.
I
LO
Core Sand
Green
Green
Fur an
Furan
Alkyd
Alkyd
sand
sand
- TSA
- TSA
isocyanate
isocyanate
Phenolic urethane
Phenolic urethane
Shell
Shell

Max.
(ppm)
2400
2400
1930
1770
1850
2070
2220
2500
2010
1690
CO
(Time)
(3 min)
(3 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(5 min)
(3 min)
Max. CO 2
(ppm) (Time)
18,100
11,400
7,990
6,750
7,750
5,540
11,500
10,880
9,720
9,890
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
Max.
(ppm)
680
540
380
430
320
460
240
310
330
330
CH,,
(Time)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(1 min)
(4 min)
(5 min)
(4 min)
HCT
(ppm)
980
1460
910
840
710
860
510
610
850
570
(Time)
CH,,
(2 min)
(6 min)
(3 min)
(3 min)
(10 min)
(1 min)
(20 min)
(2 min)
(2 min)
(7 min)
NH3
ug/1
1.0
<0.20
0.48
<0.20
0.32
0.45
0.21
0.17
<0.20
0.20
HCN
wg/i
0.63
0.91
0.64
0.85
<0.21
2.70
<0.21
<0.21
:
       Phenol  formaldehyde
1850 (5 min)
7,800  (1 min)
310 (5 min)
550 (5  min)
0.30

-------
overall emissions during the pouring of a simple cylindrical casting, such
as illustrated in Figure 1.  These results clearly indicate that the molding
sand decomposition (as for green sand)  predominates emissions produced from
thermal decomposition of the core.  These emissions may also become fugitive
emissions, (25) so it is important to bear in mind that whereas a new core
binder, such as the carbohydrate-based spirit binder, may reduce core room
emissions, it may have little effect in the pouring area.  The relative chemi-
cal simplicity of this binder indicates that a reduction in emissions in pour-
ing and shakeout areas might be possible if the molds were bonded with it.
Further development along these lines is expected.  These efforts are expected
to include quantification of the advantages which might be gained in reducing
pouring room and shakeout emissions if the carbohydrate binder is used for
molding.
                                  CONCLUSIONS

     Typical core  room emissions  include  hydrocarbons  ranging  from methane
to  the light oils  as well as aromatic compounds,  including  benzene.  Other
emissions may  include carbon monoxide, carbon  dioxide  and other  simple  organic
compounds such as  formaldehyde.   Some processes may  release amines,  ammonia,
and sulfurous  gases, depending  upon  the specific  core  binder.

     There  are essentially  two  sources of these emissions:   the  curing  oven
and the  sand binder.  In either case,  these emissions  are most often directly
vented to the  atmosphere.   They present an undesired pollution and may  have
an  irritating  odor.

     One engineering  solution  to  the problem of controlling the  fugitive emis-
sions  from  the core  room of the foundry may lie  in binder substitution.  A
new type of binder based upon  starch has  been identified as a possible  core
oil substitute,  and  it  promises to greatly reduce binder emissions  in the
core making and  baking  processes.

     A new  method of drying these carbohydrate-bonded cores employing micro-
wave energy may  also improve,  or  essentially eliminate, core room emissions
 in  the foundry.
                                        -377-

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                                   REFERENCES

 1.  Scott, W.D. and Feazel, C.E., "A Review of Organic Sand Binder Chemistry,"
     Modern Casting Tech Report, No. 765, American Foundrymen's Society, June
     1976.

 2.  Plummer, J.F., "Bonding Mechanisms of Inorganic Foundry Binders," address
     to Am. Chemical Society's Symposium on New Developments in Foundry Binders,
     Sept. 13, 1978, Miami Beach, Fla.

 3.  Schafer, R.J. and Toeniskoetter, R.H., "Industrial Hygiene Aspects of
     the Use of Sand Binders and Additives in Molds and Cores," BCIRA Con-
     ference on the Working Environment in Iron Foundries, University of War-
     wick, March 1977.

 4.  Eftax, D.S.P. and Brechter, M., "Environmental Considerations on the
     Use of No-Bake Foundry Binders," BCIRA Conference on the Working Environ-
     ment in Iron Foundries, University of Warwick, March 1977.

 5.  Wallace, R.A., "Inorganic Binders for Mold and Core Preparation," Steel
     Castings Institute of Canada, Research Report 25, March 1978, pp 127.

 6.  Nicholas, K.E.L., The CO,-Silicate Process in Foundries, British Cast
     Iron Research Association, Birmingham, U.K., pp. 223.

 7.  Scott, W.D., Bates, C.E., and James, R.H., "Chemical Emissions from Foun-
     dry Molds," AFS Transactions, Vol. 85, 1977, pp 203-208.
                                                       *
 8.  Scott, W.D., James, R.H., and Bates, C.E., "Point Source Emissions from
     Foundry Molds," Proceedings of BCIRA Conference on Working Environment
     in Iron Foundries, March 1977, University of Warwick, U.S.

 9.  Dorfmuller, A. and Schafer, R.J., "Cold Box Process-Research to Reality,"
     AFS Transactions, Vol. 8.1, 1973, pp 404-409.

10.  Crowley, T. and Apelbaum, J., "Microwave Ovens in the Foundry," Elec-
     tronic Progress,  Vol. 18, 1976, pp 8-18.

11.  Tarasescu,  M. and Dragoi, F., "General Consideration of the Use of Micro-
     wave Energy in Foundries," Metalurgia, Vol. j!9(5) , pp 246-251.

12.  Schroeder,  R.E. and Hackett, W.S., "Microwave Energy in the Foundry,"
     AFS Transactions, Vol. TT_, 1969, pp 141-145.

13.  Data drafted for  Cured Sand Committees, American Foundrymen's Society,
     Des Plaines, 111., April 1976.

14.  "Phenolic Resins," Foundry Health and Safety Guide, No. 12, American
     Foundrymen's Society, Des Plaines, 111.,  April 1976.
                                     -378-

-------
15.  Wile, L.E., "Progress in Coremaking:   Shell," Foundry,  March 1970,  pp
     50-57.

16.  Toeniskoetter, R.H. and Gardikes, J.J., "Chemistry of the Cold Box  Core-
     making Process," address to Am.  Chemical Society's Symposium on New
     Developments in Foundry Binders, September 13, 1978, Miami Beach, Fla.

17.  Toriello, L.I. and Robins, J., "Cold Box Processes - Sand and Metal Per-
     formance," AFS Transactions, Vol. 76, 1968, pp 212-221.

18.  Sahlin, L.B., "Cold Box Process - Process Engineering Studies," Modern
     Castings, February 1969, pp 17-22.

19.  Stewart, H., "Insta-Draw Process," Tech. Bui. Core-Lube, Inc., Danville,
     111., June 1977.

20.  Kiesel, R.F. and Van Oene, H., "A Method for Odor Analysis of Foundry
     Emissions," address to Am. Chemical Society's Symposium on New Develop-
     ments in Foundry Binders, Sept.  13, 1978, Miami Beach, Fla.

21.  Cummisford, B.C.,  "Curing Spirit with Microwave," Ibid.

22.  Scott, W.D. and Bates, C.E., "Decomposition  of Resin Binders  and the
     Relationship Between Gases Formed and  the Casting Surface Quality, AFS
     Transactions, Vol. 83, 1975, pp  519-524.

23.  Smith, W.A.,  "Microwaves  and Materials  Science in Foundry Applications,"
     address  to Am. Chemical Society's Symposium  on New  Developments  in Foun-
     dry  Binders,  September 13,  1978, Miami  Beach, Fla.

24.  Cole, G.S.,  "The Effects  of Microwave  Heating on  Core  Processes," AFS
     Transactions, Vol. 86,  1978,  in  print.

25.  Scott, W.D.  and Bates, C.E.,  "Measurement of Iron Foundry Fugitive Emis-
     sions,"  to be published  in  Proceedings of EPA Symposium on  Fugitive  Emis-
     sions, Hartford, Conn. May  18,  1976.
                                       -379-

-------
         OCTOBER 25.  1978
  Wednesday Morning - SESSION V

Session Chairman:   Henry J. Kolnsberg
                   Senior Project Manager
                   TRC - The Research Corporation
                         of New England
                -381-

-------
      FUGITIVE EMISSIONS PROBLEMS  AND CONTROL AT  A SURFACE  COAL MINE
                By:   Lyle D.  Randen,  Environmental Engineer
                             AMAX Coal Company

                                 ABSTRACT
     Fugitive dust control is not an exacting science and varies from region
to region depending mainly upon climate, soils, and vegetative cover.  Many
new and Innovative control techniques are infeasible due to their cost,
effect upon equipment, or other forms of environmental degradation, i.e.
water pollution.  After studying various forms of fugitive dust control, I
feel that implementation of conventional control techniques are usually the
best.

  '   Specifically, wind erosion of barren areas can be best controlled by
application of hay mulch and/or seed depending upon the length of time an
area is to be left unmined.  When using electric drive trucks, i.e. Electro-
Haul trucks, the most feasible control of pit haul road dust is through the
use of water trucks.  Chemical additives oftentimes can have a detrimental
effect upon the electrical or mechanical systems of a haulage vehicle when
used over a period of time.  Many other forms of fugitive dust control have
been recommended, i.e. irrigation sprinklers on roads, blasting mats, spray
nozzles on shovels, water bags in blasting holes, etc.  AMAX will continue
to evaluate these types of control for application at their Wyoming mines.
However, most of the tests so far have shown new techniques not feasible
due to weather extremes, costs, effect on equipment and general unworkable
situations.
                                     -383-

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     Fugitive dust takes on many different meanings when defined in the eyes
of the regulator, the environmentalist, the industrial representative, the
agriculturalist and so on.  Its definition as published in the "Prevention of
Significant Deterioration Regulations," developed by the United States
Environmental Protection Agency will ultimately be litigated.  Regardless of
the outcome of all of the interpretations or adaptations of the definition of
fugitive dust, it will continue to cause problems for all concerned.  My
remarks today are limited to those problems associated with a large surface
coal mine operating in the State of Wyoming, namely the AMAX Belle Ayr Mine.

     The Belle Ayr Mine produced some 13.3 million tons of coal in 1977,
giving it the distinction of being the largest producing coal mine in the
United States.  We will exceed this production level in 1978.  Along with the
prestige of being the largest mine comes the requests to do environmental
impact studies on the mine, i.e., air, water, wildlife, etc., inspections
from curious and serious regulators and environmental groups, salespersons,
interested citizens and so on.  Each of these groups have their own ideas
on how we should control fugitive emissions.  These range from doing nothing
to enclosing the pit and putting on a baghouse to shutting down the entire
operation.  The latter two, however, would not be economically feasible for
AMAX nor in the best interests of our Nation's energy goals.  The AMAX Belle
Ayr Mine is regulated by U.S.G.S., BLM, EPA, OSHA, MSHA, OSM, Wyoming
Department of Environmental Quality which has an Air Quality, Land Quality,
and Water Quality Division and the list appears to be broadening during each
session of Congress.  This serves only to further distort already cloudy
issues.

     Fugitive emissions sources are numerous in a surface coal mine.  They
include:

     1.  Haul road traffic - coal and overburden
     2.  Shovel-truck loading operations - coal and overburden
     3.  Topsoil removal
     4.  Blasting - coal and overburden
     5.  Truck dumping - coal and overburden
     6.  Open storage piles - not usually allowed for coal
     7.  Exposed areas including topsoil piles and grading and redistribution
         of topsoil and overburden
     8.  Haul road construction and maintenance
     9.  Train loading - coal

     A few of the above sources are amenable to conventional treatment and
are easily controlled.  The other sources of fugitive dust are not so easily
controlled both economically and technically.   Control devices or
methodologies must change with geographical locations due to climate, soil
types and conditions and differing types of equipment used to mine coal.


                                     -384-

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Electric wheel motors, 100 degree temperatures, 10-20% relative humidities,
wind chill factors of -50 degrees and strong winds, make control of fugitive
dust seem impossible.  Many natives of the State of Wyoming also feel it is
impractical given existing dust levels.

     There are several approaches to control of fugitive dust.  AMAX has
experimented with a number of these with limited success.  When a new control
is suggested, before any hands-on experimentation, one must go through a
rigorous review of the control and potential problems.  We review new control
practices and techniques for their economical impact, i.e., cost per ton of
coal produced, technical feasibility such as the applicability of water spray
system operating during freezing conditions, safety considerations, effect on
operating equipment, secondary environmental effects, area resource depletion
and product availability.  Many of the control techniques that I criticize
may well be techniques or methods that others have found suitable.  I am only
reporting findings as they apply to our mine, and those that  generally would
apply to surface coal mines operating  in the "Powder River Basin" of Wyoming.

     Let us take each of the sources I have previously listed and discuss
fugitive dust problems and control of  them:

     1.  Haul Road Traffic.  For those of you not directly familiar with our
Belle Ayr Mine, we have two types of haul roads,  i.e., overburden and coal.
They sometimes cross each other and sometimes  are one and the same.  The life
of  a haul road can vary from several days to several years.   As  such, haul
roads cannot be considered permanent as can the  entrance roads  leading  into
the mine.  Most mines are being required by the  Wyoming Department of
Environmental Quality, Air Quality Division, to  "hard surface"  all entrance
roads leading into the mine as part of their "permit-to'construct" application.
AMAX is  experimenting with soil binders and a  double  chip and seal surface or
a two inch asphalt mat to meet these requirements.  There are a number  of
different fugitive dust  control strategies  for haul road traffic.  Most
regulatory agencies  recognize  road watering, silt  content of  the soil,  tire
size and vehicle  speed in  calculating  emissions  from  haul roads (U.S. EPA,
1973).   The  U.S.  EPA publication AP-42 also  establishes  a  climatic factor  for
rainfall using  0.01  inches of  rain  for 100%  control of  fugitive dust.   In
Wyoming the  number of days per year  receiving  more than 0.01  inches  of  rain
 is 100  (U.S.  EPA, 1975).   Therefore,  our  climatic factor is  265. or  rainfall
controls 100%  of  fugitive  dust 28%  of  the time.   Our  pro-    365  blem is then
 controlling  fugitive dust  the  other 72% of  the time.   This  could be  done with
water  trucks, water  trucks with  chemical  additives,  chemically treating the
 roads,  hard  surfacing the  haul road or eliminating the haul road and replacing
 it with some other means of  transporting  the coal or overburden in a dust
 free manner.
                                      -385-

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     My  first  choice would be  to operate water trucks In a manner that
 simulates  a  rainfall event on  the haul roads  comparable to the rainfall event
 noted  in AP-42.  This  control  could also be altered by using something other
 than a water truck  to  apply  the water, i.e.,  an irrigation system.  This
 system,  however, cannot be used to control fugitive dust during the freezing
 conditions unless an antifreeze is used in conjunction with the water.
 Unfortunately, the  water and antifreeze make  the road slippery and create a
 severe safety  hazard.  Also  the height of the spray necessary to cover a 100'
 wide roadway,  creates  a mechanical nightmare  with water being sprinkled almost
 as high  as the truck cab.

     Water trucks with chemical additives have proven to be very costly.  If
 we use the chemical for 120  days per year we  have spent a lot of money;
 potentially  enough  to  buy another water truck that can be depreciated over
 several  years.  Other  chemicals with which I  am familiar cost large sums of
 money  at their intital applications, but are  reduced in cost on subsequent
 applications but require continuous maintenance.  Some are corrosive, some
 have a potential impact on the electric wheel motors, and others cake the
 underside  of the equipment prohibiting routine maintenance without high
 pressure steam or gasoline cleaning treatment.  The main factor in making
 this analysis  is that  the water truck and operator are still essential to
 putting  on the chemical.  We must also be careful that any chemical used will
 not enter  a water course and result in water  pollution or a fish kill.

     Chemical  treatment and hard surfacing of haul roads can be treated as if
 they were  the same  because the constraints that limit their use within a sur-
 face coal  mine are  the same.  Chemical treatment or hard surfacing of a haul
 road is very expensive due to the depth the application would have to be made
 to in  order  to withstand the weights of the haul trucks.  An unloaded over-
 burden truck weighs approximately 35 ^ons and a loaded truck will weigh in
 the 145 ton range.  The chemically treated road would pot hole out as would
 a hard surfaced road.  Spillage onto the road would eventually cover the
 chemically treated  surface as well as a hard  surface.  The road is probably
 not in existence long  enough to warrant this  type of expenditure.  Additionally
 most mines use a motor grader to rip the road and then apply aggregate for
 traction during winter, i.e., snow and freezing conditions.

     The movement of coal and overburden in other "dust free" manners is
 being  explored by AMAX and other coal companies.  I am talking about the use
 of enclosed conveyors  for long haul situations.  This alternative is not only
 being  explored from a  dust reduction standpoint, but also as a method to
 achieve greater economic efficiency.   However, there are still some unresolved
 problems concerning conveyor system usage in  AMAX.

     Given the above brief explanation of money, technical shortcomings,
mechanical hazards and unworkable situations, I believe that AMAX will


                                     -386-

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continue to utilize water trucks for fugitive dust control on haul roads.
We will work with vehicle speeds and other readily available, proven techniques
to control fugitive dust.  We will also continue to explore the use of
chemicals  in water trucks, chemical treatment of roads and hard surfacing
roads, but probably would not expend any large sums of money on implementation
unless frequent violations of the ambient air quality standards for the State
of Wyoming are noticed.  We will continue to look at ways to increase water
truck efficiency.  This includes the installation of a surge tank at Belle
Ayr for reduced cycle times and larger water truck tanks.  In areas where
water is not so abundant the use of chemicals may be quite advantageous in
controlling fugitive dust.  My discussion related only to our situations.

     2.  Shovel-Truck Loading Operations.  Both overburden and coal are re-
moved utilizing a truck-shovel operation at the AMAX Wyoming mines.  Typical
shovel bucket sizes are 24 cubic yards on the overburden shovels and 40 cubic
yards on the coal shovels.  Fugitive dust control on the shovels is a potential
problem.  A great deal of the time the material loaded is moist enough or
frozen to the point that it is not a problem.  Problems occur during the hot,
dry, windy days of the summer months.  I have worked with the idea of a spray
system mounted on the shovel but feel that a potential safety hazard exists
with water being sprayed around a shovel that utilizes a very high voltage
line  for power, i.e., 4160 volts.  The spray system would not penetrate the
coal  or overburden surface enough to adequately control the  dust.  Other
potential problems include alteration of the heating value of the coal by
adding too much moisture, which is probably  insignificant, coal sticking in
the trucks and loadout silos, overburden sticking to the truck beds,
limitation of the shovel operators' visibility, and overwatering of  the load-
ing area making  it slick for  truck and sho.vel operation.  Presently,  during
dusty conditions, our water  trucks will back up above  the shovel and shoot
water onto the bench of  coal  or overburden  as a short-term mitigating measure.

      3.  Topsoil removal.   Surface mine  operations are required to  save top-
soil  for later use.  Topsoil  removal  is  accomplished with pan scrapers.   Dust
eminates  from working  areas,  haul  roads  and storage piles.   To eliminate
this  fugitive dust problem and  avoid  potential  soils  contamination by using
chemicals, we require  all  topsoil  removal  operations  to be  accompanied by a
water truck.  If the water truck breaks  down during the topsoil removal
operation  and conditions are dusty,  the  operation will be shutdown until  the
water truck  is back  in service.  All  of  AMAX topsoil removal operations  at
Belle Ayr  are on a contract  basis.   This requires the water truck or trucks
be included  in  the bid.  We  are presently  experimenting with pre-wetting areas
to be stripped  of  topsoil  with  an  irrigation system and staged stripping of
 topsoil  to take  advantage of spring rains.

      4.   Blasting  -  Coal and Overburden.   AMAX normally will blast 75% of the
overburden and  100%  of the coal removed.   This  is done to increase shovel


                                     -387-

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efficiency.  I have helped with experiments incorporating the use of water
sprayed over the area to be shot, water bags put down the hole on top of the
explosive, differing types of energizing systems to actuate the shot (nonel,
prima cord) with no appreciable reduction in dust levels from the shots.
Some people have suggested the use of blasting mats to control dust.  Blasting
mats were developed to control flyrock, not dust.  With all of the safety
(MSHA) regulations, OSM regulations and other common sense controls, I am of
the opinion that there is very little or nothing we can do to control fugitive
dust from blasting operations.  Maybe blasting operations should not be
considered as a problem as it is short-term, has limited control possibilities,
and most of the dust settles in a short distance from the shot.

     5.  Truck Dumping - Coal and Overburden.  Truck dumping of coal into a
hopper can be easily controlled.  There are two approaches:  a baghouse
system drawing a negative air pressure on the hopper, or using a spray bar
system creating a fine water mist over and in the truck dump.  Such systems
are commercially available and as such do not present an unsolveable problem.
Overburden truck dumping is a source of fugitive dust and I am not familiar
with any types of control other than reducing drop heights from the trucks,
limiting the heights of piles within the pit to keep it out of the wind,
orienting dump areas at right angles to prevailing winds, and watering turn
around and backup areas next to the overburden dump.

     6.  Open Storage Piles.  Open coal storage piles are usually not
allowed by the State of Wyoming Air Quality Division.  Open storage of topsoll
is controlled in the same way that we control exposed areas as discussed be-
low.  There are a number of chemical binders, mechanical methods and other
control strategies that can be implemented to control fugitive dust from coal
storage piles.   As I do not have any actual experience with these, I will not
discuss their application.

     7.  Exposed Areas Including Topsoil Piles and Grading and Redistribution
of Topsoil and Overburden.  I have developed a wind and water erosion control
strategy for the AMAX Belle Ayr Mine as per the OSM requirements.  Briefly,
AMAX relies upon SCS established practices for controlling wind erosion of
exposed areas.   Included within controlling fugitive dust from exposed areas
is limiting vehicular traffic to established roads or staking off non-travel
areas.  The area of soil exposed and length of time that it is exposed should
be kept to a minimum.  There are several practices that can be utilized to
control fugitive dust from exposed areas.  Usually, the lowest cost practices
are the most effective in controlling erosion.  Straw mulch or hay mulch at
an application rate of two tons per acre can control up to 90% of the wind
erosion.   The mulch should be anchored to be effective in controlling erosion.
                                     -388-

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Practices to reduce fugitive dust;

           Practice

1.  Disturbed Area Stabilization
    (with mulching only)
2.  Disturbed Area Stabilization
    (temporary seeding potential
    fertilization)

3.  Disturbed Area Stabilization
    (permanent seeding potential
    fertilization)
Condition Where Applicable

On areas to be bare less than 6
months or where seedings cannot
be made.

Areas which would remain bare for
one year or less before
permanent grading and seeding.

On bare areas where permanent
vegetation is needed.
     Fugitive dust from exposed areas can be effectively controlled if mulch-
 ing, seeding and fertilization operations are conducted as soon as possible
 after  the  disturbance.  Of course, final and permanent reclamation is the
 ultimate answer to controlling fugitive dust from exposed areas.

     8.  Haul Road Construction and Maintenance.  Haul road  construction is
 usually done by backfill  operations utilizing dozers  and front end loaders
 while  maintenance is  done by motor graders.  The only realistic control again
 dictates the use of water trucks  to control fugitive  dust.   Please note
 discussion of chemical usage in Part  I, Haul Road Traffic.

     9.  Train Loading -  Coal.  Actual monitoring tests have shown this source
 to be  of little significance when left uncontrolled.  Coal  is loaded by
 gravity  flow  from a  4 silo  arrangement into a train driven  underneath.  The
 moisture content of  the stored  coal probably reduces  emissions more  than any-
 thing.  There are spray bar systems with  or without chemical additives  or
 binders  available for use.   Our experiments have  shown  to date that  these
 systems  are not necessary.   Future tests  may require  further scrutinization
 of these controls.

      Other sources  of fugitive  dust  contained within  the pit of a surface
 coal mine  produce  insignificant emissions when compared to  those discussed
 already.   I have  limited  the scope of this paper to those fugitive dust pro-
 blem areas and potential  control  techniques that I am familiar with.  I am
 sure that there are a number of other control techniques that merit
 consideration and experimentation by the AMAX Coal Company.  AMAX is dedicated
 to continued evaluation of these types of new and innovative techniques for
 application at the Belle Ayr Mine.  We have found by actual monitoring that
 county gravel roads probably produce as much if not more fugitive dust than
 the mines.  That is why we are hard surfacing light  duty access road utilized
                                      -389-

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by our employees going to and from work.

     A lot of the issues concerning "fugitive emissions problems and control"
will eventually be resolved by the courts.  We must not lose sight of the
Nation's energy goals, and the fact that the cost of controlling fugitive
emissions will ultimately be borne by the consumer in the form of increased
electrical rates and product values.  Fugitive emissions control should not
neglect public health considerations as related to particle size distribution.
It is my contention that a large percentage of fugitive dust falls out of the
air before it ever hits the pit boundaries, let alone before it reaches
property lines.  Property line concentrations should be regulated levels, not
pit concentrations.  Pit concentrations are already being monitored by the use
of dust pumps as required by MSHA and compliance with these standards is
ongoing at Belle Ayr.  These tests relate to the respirable fraction of the
dust.

     We need to take a realistic approach to fugitive emissions control.  New
technology must be given time to be proven both technically and economically.
Thank you for the opportunity to speak at this symposium.  I hope you find
my remarks enlightening and challenging for without challenge there would be
no change.
                                     -390-

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AIRCRAFT TURBINE ENGINE PARTICULATE
      EMISSION CHARACTERIZATION
 John D. Stockham, Erdmann H. Luebcke
       IIT Research Institute
      Chicago, Illinois, U.S.A.
                  and
           Larry Taubenkibel
 DOT - Federal  Aviation Administration
       Washington,  D.C., U.S.A.
                -391-

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                                    ABSTRACT
     A particulate matter sampler is described along with operational expe-
rience and the data obtained using the sampler on the JT8D and JT9D aircraft
turbine engines.  The sampler acquires a sample of the exhaust particles
emitted during the ground operation of the engine and permits the characteri-
zation of the mass concentration, elemental composition, particle size dis-
tribution, and particle morphology.  Mass concentration is obtained
gravimetrically.  Elemental composition is obtained by energy dispersive X-ray
and particle size and shape by electron microscopy and image analysis.  Par-
ticle size data is also obtained with the Electrical Aerosol Analyzer.

     The sample is extracted from the exit plane of the engine.  The sampling
probe geometry corresponds to the FAA's recommended methodology for gaseous
emission sampling.  The extracted sample is conditioned through dilution to
minimize local condensation, particle deposition, and sample bias before col-
lection on substrates suitable for analysis.
                                    -392-

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     THE PHYSICAL AND CHEMICAL CHARACTERIZATION of particles emitted by air-
craft turbine engines has not received comprehensive investigation.  There-
fore, a sampling system was designed and constructed to collect particles
from aircraft turbine engines (1,  2).*  The sampler is specifically designed
to collect representative samples  of particulate matter from the exhaust at
the exit plane of low bypass ratio, mixed flow, and high byp'ass ratio aircraft
turbofan engines operating in an engine test cell.  These engine types are
represented in the current commercial fleet by the JT3D, JT8D, and JT9D
series of engines.  The sampler uses a mixing type sampling rake, a special-
ized aerosol transport and conditioning system,'and sample collection near
the engine to minimize particle deposition, re-entrainment, and agglomeration
during transport.  A feature of the sampler is the bifurcation of the ex-
tracted exhaust sample - a large portion for bulk analysis and a smaller
portion for detailed particle characterization.
     SAMPLER DESCRIPTION

     A flow diagram of the sampler is shown in Figure 1.  A "diamond" shaped
sampling rake mounts directly behind the engine exhaust plane.  An extraction
nozzle is located at the midpoint of each leg of the diamond.  The four
nozzles are evenly spaced on an arc whose radius is 62% of the engine's exit
plane radius.  The leading edge of the nozzle extends about ten diameters
upstream of the support structure.  The nozzle diameters are 0.170 ± 0.008 cm.
The geometry of the rake corresponds to that recommended by the Federal
Aviation Administration (FAA) for gaseous emission sampling and has been
shown to give comparable results to a 24 sampling nozzle rake system (3).
The four sampling nozzles are manifolded to provide a composite sample.  The
manifold is connected to the primary diluter via a flexible coupling that
accommodates movement of the engine during testing.

     The function of the primary diluter is to condition the extracted partic-
ulate matter sample.  The sample is cooled without passing through a dew
point and diluted to reduce particle agglomeration effects.  The  unique
design of the diluter reduces wall losses and aids in the preservation of
particle mass and particle size distribution  (4, 5).  The diluter consists of
a  porous tube housed within a larger tube.  Clean, dry, metered,  compressed
air is delivered to the annular space at four locations and  flows through  the
porous inner tube providing a clean boundary  layer that reduces particle
deposition  and  subsequently mixes with  the  sample to provide dilution and
temperature control.
      ^Numbers in parentheses designate References at end of paper.
                                      -393-

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     After conditioning, the sample is bifurcated.  The majority of the
sample is transported to the mass sampling turret where the particulate
matter is removed by filtration onto tared Gelman, type AE, glass fiber
filters, 142 mm in diameter.  A smaller portion of the sample is adjusted in
concentration by a secondary diluter similar in design to the primary diluter
and transported either to the Electrical Aerosol Analyzer (EAA) for real-time
particle size distribution measurement or for collection onto membrane filters
and electron microscope grids for subsequent analysis of particle size, shape,
and elemental composition.  The membrane filters used are 0.03 pm pore size
Nuclepore filters, 47 mm diameter.

     With the exception of the EAA, the sampler is designed for operation in
close proximity to an operating turbine engine.  All functions of the sampler,
therefore, are remotely controlled from a centralized control panel that can
be located up to 25 feet from the filtration units in a safe location such as
the test cell control room.  The EAA continuously malfunctioned in the test
cell environment despite efforts to provide a suitable sound protection enclo-
sure.  As a result, the EAA is operated in the test cell control room.

     Flow control valves for the sampler are located downstream of the parti-
cle collection sites to eliminate particle deposition in the valve assembly.
This requirement imposed operational constraints in the system—each sample
has to be acquired sequentially and flow switching procedures must be care-
fully performed to prevent rupture of the filters.  Also, because the ex-
tracted sample flow from the engine is not measured directly, the primary
diluter flow and the total sample flow have to be accurately determined.  The
dilution flow rates are measured by precision drilled orifices; total flow is
measured with a hot-wire anemometer.  The uncertainty in total flow measure-
ment is ±0.09 std. m3/hr. while the dilution flow is repeatable to approxi-
mately ±0.1 std. m3/hr.   The maximum error in the extracted sample flow
measurement occurs at idle power and is on the order of 10%.

     The turret assemblies for sample collection provide positions for six
filters.   Samples, thus, can be acquired at five engine power settings —
idle, approach, cruise,  climb-out, and take-off — before the engine needs to
be shut down and the filters recovered.  The sixth turret position is a dummy
used during start-up, shut-down, and while power settings are being changed
and engine operation stabilized.

     The sampler is designed for isokinetic sampling of the exhaust from the
JT8D and JT9D engines at power settings from idle through cruise.  At climb-
out and take-off power,  sonic conditions are approached at the engine's exit
plane and sampling at this rate would cause severe flow complications re-
sulting in modification of the extracted exhaust particles.  The flow through
the extraction nozzles was, therefore, limited to a local Mach number of 0.8.
Extracted sample flow ranged from 0.9 std. m3/hr. to 4.8 std. m3/hr. for
engine power settings from idle to take-off (6).
                                     -394-

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     TEST SITE AND DATA ANALYSIS PROCEDURES

     The particulate matter sampler was operated at United Airlines'  San
Francisco, Ca., Maintenance Facility on JT8D and JT9D aircraft turbine en-
gines.  Figure 2 shows the sampler set-up in a JT9D test cell.  Due to Unit-
ed1 8 fleet needs, sampling time was at a premium and several different engines
were used during the test series.  The engines tested are given in Tables 1
and 2 along with data on the mass emission rate and the particle size distri-
bution of the exhaust particles as determined by electron microscopy and image
analysis.  In addition, particle sized distribution measurements were made
with the EAA and particle shape was determined by image analysis.  Two fuels
were used during the test series, pearl kerosene (PK), a high hydrogen, low
aromatic content fuel, and JET A, a standard commercial aircraft turbine
engine fuel with a lower hydrogen and higher aromatic content.  The use of two
fuels permits the determination of the effect of fuel composition on emis-
sions.  A single batch of PK fuel was purchased and stored at United's facil-
ity.  Its composition, therefore, was constant throughout the tests and
repeatability measurements were possible.  JET A fuel composition varied
during the tests.  All fuels were sampled and analyzed; significant data is
given in Table 3.

     Mass emission rates were determined by differential gravimetric analysis.
A Gelman, type AE, glass fiber  filter was used to collect the particulate
matter for mass determination.  The filters were weighed on an analytical
balance before and after sample collection and corrected for  shifts  in weight
due  to hygroscopic effects with control filters.

     Particle size data was obtained by two methods.  One method used, the
Electrical Aerosol Analyzer (EAA), provided a real-time measure of the parti-
cle  size  distribution.  The EAA used was Model 3030, Thermo-Systerns,  Inc., St.
Paul, Mn.  The  instrument was operated  in  accordance with the operating and
service manual  provided with the  instrument.

      The  second  procedure  used  for particle  size analysis was electron micro-
scopy and image analysis.   The  samples,  collected  on Nuclepore membrane  fil-
ters or  carbon coated electron  microscope  grids attached  to  the membrane
filter,  were used in the  analysis.  The electron microscope  used was the  JEOL-
100C analytical scanning/transmission microscope equipped with an  energy
dispersive X-ray system for elemental analysis.  After  applying  a  thin film of
gold to  the  filter surface with a Hummer II  plasma specimen  coater,  the sam-
ples were observed and photographed in the scanning microscope  at  several
magnifications ranging from 10,000 to 100.000X.  A magnification of 30,OOOX
was found to be optimal for particle  size and shape analysis.  Particle size
 and shape analysis were performed by  interrogating the electronphotomicro-
 graphs. with an Imanco Quantimet 720 Image Analyzer.  Particle size was com-
 puted from the area measurement of each particle.   The particle size reported,
 thus, represents the diameter of a circle of area equal to that of the parti-
 cle.
                                       -395-

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     Particle shape was determined using the image analyzer and interrogating
the particles for their area and perimeter.  A two-dimensional shape factor
was then calculated from the ratio A/P2.  This ratio was plotted as a function
of the equivalent area particle diameter.

     Elemental composition of the particles was determined while the particles
were under observation in the electron microscope.  A Kevex energy dispersive
X-ray spectrometer coupled with the Tracor/Northern 880 X-ray analysis system
was used.
     RESULTS AND DISCUSSION

     MASS EMISSIONS — Mass emission data are reported in Tables 1 and 2 and
plotted for the JT8D engine as a function of primary air flow in Figure 3.
The data show an increasing emission rate with power.  The emission rate
ranged from 0.15 kg/hr at idle to a range of 0.25 to 4.62 kg/hr at climb-out
and 0.76 to 1.79 kg/hr at take-off.  Data for the JT9D engine show a similar
trend and the same order of magnitude.  However, primary air flows for the
JT9D engine are significantly greater.  Primary air flows as a function of
engine power is given in Table 4.  With the restricted sampling time avail-
able, 12-30 minutes depending on the operating mode, and the low emission
rates for the JT8D and JT9D engines, the gain in filter weights were only a
few milligrams.  Additional testing with longer sampling times are needed for
a more accurate determination of mass emission rates.  Earlier data (2) col-
lected from a TF-30 engine suggest the sampler can reproduce mass concentra-
tion data within ±2% at the cruise power setting for this engine.  Effects of
engine and fuel variability are discernible, however.  The JT8D-7 engine,
648735, gave lower emission rates than the other engines and the JT8D-15
engine tested with both JET A and PK fuel gave a lower emission rate with the
PK fuel.

     PARTICLE SIZE DATA — Particle size data obtained by electron microscopy
and image analysis are reported in Tables 1 and 2 and summarized in Tables 5
and 6.  For the JT8D_engines, operating on JET A fuel, the average geometric
mean particle size, dg increased with engine power.  At idle, dg was 0.045 urn,
at approach dg was 0.068 ym, at cruise and climb-out dg was 0.078 ym, and at
take-off dg was 0.084 ym.  Particle size is influenced by fuel type; PK fuel
gave smaller particle sizes.  This is consistent with the lower mass emission
rate found for the engine when operated on PK fuel.  Also consistent is the
performance of JT8D engine 648735.  This engine, which produced the lowest
emission rates, also produced the smallest particle sizes.  The geometric
standard deviations for the particle size distributions ranged from 1.6 to
2.3.  Engine 648735 gave the widest distribution of particle sizes.  The JT9D
engines gave similar trends to the JT8D engines, but indications are that the
particles are smaller.
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      Particle  size distribution data were also obtained with the EAA.  Typical
data for the JT8D and JT9D engines are plotted in Figures 4 and 5.  These data
support  the results obtained by the electron microscope and image analysis
measurements.  Higher power settings produce a greater concentration of parti-
cles in  all sizes ranges above about 0.02 ym.  Below 0.02 \mt data is con-
flicting but the performance of the EAA is known to be erratic in this
range (7).  Particle concentration for the JT8D engine is about one order of
magnitude greater than  for the JT9D engine.  The influence of fuel composition
on particle size is illustrated in Figures 6 and 7 for the JT9D engine at ap-
proach and take-off power.  At all power settings, PK fuel produced few parti-
cles.

      PARTICLE  SHAPE —  Particle shape data shows the particle structure is
more complex at  climb-out and take-off than at the lower power settings.
Figures  8 through  11  illustrate this effect.  The effect is evident from the
photographs shown  in  Figures 12 and 13.  As an aid in interpreting the shape
factor:,  A/P2,  Table  7  is presented.  The shape factor for a disc, the two-
dimensional representation of a sphere, is 1/4 ir or 0.0795.  A 5-chain agglom-
erate has a shape  factor of 0.0159; a 10-chain, 0.0078; and a 50-chain,
0.00016.  Thus,  as the shape factor decreases the particles are  less spherical
and more highly agglomerated.  Generally, particles with shape factors above
about 0.03 can be  considered single particles trending  toward a  spherical
shape-  As shown in Figures  9 and 11, the very large  exhaust particles have
small shape factors and are, thus, highly agglomerated.  Idle power  produces
relatively small particles  of  simple  shape while  climb-out and take-off power
produces a wider range of  particle sizes  of more  complex shape.

      ELEMENTAL COMPOSITION —  The elemental  composition of  the individual
exhaust  particles was determined  by  energy dispersive X-ray  techniques.  No
 spectrum was obtained indicating  the  particle composition  is essentially
carbon.
      CONCLUSIONS

      The particulate matter emitted during the test cell operation of the JT8D
 and JT9D aircraft turbofan engines was characterized using a sampler designed
 expressly  for  this purpose.  The particles are principally carbon and less
 than 0.1 ym  in size.  Particle size increases with engine power.  At idle, the
 average geometric mean particle size was 0.045 ym and at take-off, 0.097 ym
 for the JT8D engine operating on JET A fuel.  Particle size is influenced by
 the fuel composition.  PK fuel with its higher hydrogen, lower aromatic, and
 higher smoke point content gave smaller exhaust particles.  Particle shapes
 are tnore uniform and trend toward sphericity at idle; at climb-out and take-
 off the particle structures are more varied and complex.  The mass emission
 rate  for  the JT8D engine was 0.15 kg/hr at idle and ranged from 0.76 to 1.79
 lcg/hr  at  take-off.  PK fuel produced lower emissions than JET A fuel.  Vari-
 ability among  the engines tested was noted.  The limited data available indi-
 cate  the  JT9D  produces less particulate matter than the JT8D.  Particle
 concentration  data show approximately an order of magnitude difference between
 the JT8D  and JT9D engines.
                                      -397-

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     The results indicate that the sampler provides a valid sample of the
particles present at the exhaust plane of aircraft turbine engines.
     ACKNOWLEDGEMENT

     The work reported was sponsored by the United States Department of
Transportation -Federal Aviation Administration under contract DOT-FA75-WA-
3722.  The assistance of Messrs. Paul Campbell and Ralph Johnson of United
Airlines and Dr. Donald Fenton of New Mexico State University is gratefully
acknowledged.
     REFERENCES

1.   D.L. Fenton, "Turbine Engine Particulate Emission Characterization,"
     Phase I Report to Federal Aviation Administration under Contract DOT-
     FA? 5-WA-3722, Report No. FAA-RD-76-141, September 1976, National Tech-
     nical Information Service, Springfield, Va. 22161.

2.   D.L. Fenton, E.W. Nordstrom, E.H. Luebcke, "Turbine Engine Particulate
     Emission Characterization," Phase II Report to Federal Aviation Admin-
     istration under Contract DOT-FA75-WA-3722, Report No. FAA-RD-77-165,
     October 1977, National Technical Information Service, Springfield, Va.
     22161.

3.   A.J. Fiorentino, et al., "Evaluation of Federal Aviation Administration
     Engine Exhaust Sampling Rake," Final Report, PWA-5534, United Technolo-
     gies Corp., East Hartford, Conn., NASA Contract No. NAS3-19447, June
     1977.

4.   M.B. Ranade, "Sampling Interface for Quantitative Transport of Aerosol,"
     Report to Environmental Protection Agency under Contract 68-02-0597,
     December 1973, Environmental Protection Agency, Research Triangle Park,
     N.C.  27711.

5.   M.B. Ranade, "Sampling Interface for Quantitative Transport of Aerosol,"
     Report to Environmental Protection Agency under Contract 68-02-1295, July
     1976, Environmental Protection Agency, Research Triangle Park, N.C.
     27711.

6.   D.L. Fenton, E.H. Luebcke, E. Nordstrom, "Physical Characterization of
     Particulate Material from a Turbine Engine," Department of Mechanical
     Engineering, New Mexico State University, Las Cruces, New Mexico.  Paper
     to be presented at the ASME Gas Turbine Conference and Product Show, San
     Diego, Ca., March 12-15, 1979.

7.   G.J. Sem,  "Design and Application of an Electrical Size Analyzer for
     Submicron Aerosol Particles," Thermo-Systems, Inc., 2500 N. Cleveland
     Ave., St.  Paul, Mn.  55113.  Presented at the 21st Annual Instrument
     Society of America Analysis Instrumentation Symposium, Philadelphia, Pa.,
     May 6-8,  1975.

                                     -398-

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              Table  1 — Summary of Turbine Engine Sampling Data - JT8D
                  Engine
                  Number
Fuel
Operating
Mode
Idle
Approach
Cruise
Climb-out
Take-off
Idle
Approach
Cruise
Climb-out
Take-off
Idle
Approach
Cruise
Climb-out
Take-off
Idle
Approach
Cruise
Climb-out
Take-off
Idle
Approach
Cruise
Climb -out
Take-off
Primary
Air
(kg/sec)
16
33
50
61
68
17
33
SO
62
69
17
33
49
61
66
17
33
50
62
69
17
33
50
62
69
Particle
Emission
(kg/hr)
0.15
1.00
1.78
2.97
0.95
__
0.30
1.01.
4.62
—
__
0.34
0.25
0.25
0.76
__
0.24
1.12
0.74
1.38
__
0.08
0.24
1.27
1.79
Particle Size
Distribution1

(dg, um)2
0.052
0.086
0.081
0.096
0.099
0.042
0.067
0.092
0.088
0.097
0.043
0.054
0.069
0.049
0.060
0.042
0.066
0.071
0.079
0.080
0.032
0.043
0.079
0.075
0.077

(Og)3
1.7
1.7
1.7
1.6
1.7
1.7
1.8
1.8
1.9
2.0
1.6
2.1
2.0
2.3
2.2
1.7
1.7
1.9
1.6
1.6
1.7
1.8
1.9
1.8
1.9
1/10/78  JT8D-7     654957    JET  A
4/24/78  JT8D-15   648796   JET A
4/25/78  JT8D-7    648735   JET A
6/20/78  JTfln-15   696572   JET A
4/24/78  JT8D-15   648796   PK
 'Obtained by electron microscopy and  image analysis
 2Geometric mean particle  diameter
 'Geometric standard  deviation
               Table  2  — Summary  of  Turbine  Engine  Sampling  Data - JT9D-3A
Sample
Date
1/9/78
4/21/78
6/21/78
6/22/78
4/21/78
Engine
Number
662734
663031
663082
662794
663031
Fuel
JET A
JET A
JET A
JET A
PK
Operating
Mode
Climb-out
Take-off
Approach
Take-off
Idle
Approach
Cruise
Climb-out
Cruise
Climb-out
Approach
Take-off
Primary
Air
(kg/sec)
99
111
62
111
30
62
82
99
82
99
62
111
Particle
Emission
(kg/hr)
_
0.60
2.87
0.32
0.22
1.33
Particle Size
Distribution1
(dR. urn)2
0.084
0.117
0.054
0.077
0.041
0.047
0.040
0.041
0.045
0.054
0.050
(Qg)}
1.6
1.6
1.8
l.S
1.5
1.7
1.8
1.7
1.6
1.6
1.9
       'Obtained by electron microscopy and image analysis
       'Geometric mean particle diameter
       'Geometric standard deviation
                                             -399'

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     Table 3 — Significant Fuel Analytical Data
     Analysis	             JET A             PK

     Hydrogen Content, %           13.05-13.65         14.25
     Aromatic Content, %              17-20              1
     Naphthalene Content, %          1.6-2.5            0.1
     Olefins Content, %                1-2               1
     Smoke Point, mm.                 20-21             35
          Table 4 — Primary Air Flow as a Function of
                     Engine Power
                                   Primary Air Flow (kg/sec)
          Power Setting                 JT8D      JT9D

          Idle                           16         30
          Approach                       33         62
          Cruise                         50         82
          Climb-out                      62         99
          Take-off                       69        111
Table 5 — Particle Size of JT8D Emission as Obtained by
           Electron Microscopy
                                                 Effect of Fuel on
                         Geometric Mean           Geometric Mean
                       Particle Size, ym1        Particle Size, um
Operating
   Mode                Range         Aver.        JET A       PK

Idle                0.042-0.052      0.045        0.042     0.032
Approach            0.054-0.086      0.068        0.067     0.043
Cruise              0.069-0.092      0.078        0.092     0.079
Climb-out           0.049-0.096      0.078        0.088     0.075
Take-off            0.060-0.099      0.084        0.097     0.077

     A fuel
                                -400-

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Table 6 — Particle Size of JT9D Emission as Obtained by
           Electron Microscopy
Operating
   Mode

Idle
Approach
Cruise
Climb-out
Take-out
     A fuel
                       Geometric Mean
                     Particle Size, van1
   Range
0.047-0.054

0.040-0.084
0.077-0.117
Aver.

0.041
0.051
0.041
0.056
0.097
                             Effect of  Fuel on
                              Geometric Mean
                             Particle Size, un
JET A
PK
0.054     0.054


0.077     0.050
     Table 7 — Particle Shape Characterization
      No.  of  Particles  in
       Agglomerate Chain

               1
               3
               5
              10
              50
          Aspect Ratio
               1/d

              1:1
              3:1
              5:1
              10:1
              50:1
                      Shape
                     Factor
                      A/P2

                     0.0795
                     0.0265
                     0.0159
                     0.0078
                     0.00016
                                  -401-

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Monitold

 /  3/4" Flexible Coupling
Sampling
Probe Assembly
           2  Stainless Stetl

           l" Vac. Hose Bypass Line
                                           Orifice
                                           Indexer
                                                  Pressure
                                                  Regulotor
                                                      \  30psig
               Porticulote
               Filter

                   Dryer
                                  Thermocouple

                        (4) Electrical Heaters
                            Vorioc Controlled
                                                                              •*- Compressed Air
                                                                                       lOOpsig
                                                              .Secondary Diluter Orifices
                                                                Pressure Regulotor
                                                                          40psig
               Moss- Sampling Turret
                  Sound Enclosure
                        I" Vac  Hose
                                       l_
            Absolute
             Filter
         —a
                                   Thermocouples
                                                                          Sample Line
                                                                       j   To EAA
                Hot-WIre
                Anemometer
                3-Way  I"
                Control Valve
                                                       Flowrneter
Roots Rotary
Vacuum Pump
                                                                       I
                                                               3-Woy 3/4"
                                                               Control Valve
                                                                                    |/2" Motorized
                                                                  Gast  Vacuum Pump
                       Flow Dampers pi



                         2" Motorized
                         Bleed Valve
           Fig.  I -  Schematic diagram of  the engine exhaust participate sampler
                                            -402-

-------
                      Flexible Coupling
   ENGINE  TEST CELL
ENGINE CONTROL ROOM
Fig. 2  - Typical  layout  for  FAA - IITR1  sampler in  an
engine  test cell
                        -403-

-------
       I0c
£

O
'5»
.52

UJ
      0.
                        II  IT
            Data
            Envelope
        10            50   100

               Primary Air  Flow, kg/sec
Fig.  3 - Mass emissions  for  JT8D
JET  A   fuel
                  -404-

-------
9
3
                  JT8D-I5 Engint 69572
                   JET A  Fuel
                     • Tokt-off
                     O Approoch
                     x Idlt
       .001
                            Porticle  Sizt,
 Fig. 4 - EAA  particle  size  data  for the  JT8D engine
                              -405-

-------
    I01
    I06
    IOB
o»
e
z
<
    I0f
                      I I I
                                                     i   i i M i r
     .001
                  JT90  Engine  663082
                  JET A Fuel
                     • Take-off
                     O Approach
                     x Idle
I  I I  I 11 ll	I    I  I  I I 11 ll	I   III I I
.01
                           O.I
1.0
                          Particle  Size,
  Fig.  5  -  EAA  particle  size  data  for  the  JT9D  engine
                          -406-

-------
I07
I06
I0a

 10'
 I01
         T   I
                                                       II I
                           ••^
                                         1}
                                                <<
              JT9D Engine Approach
               O   JET A  Fuel
               •   PK  Fuel
                                                      <*
                                                      \  —
t 	i   i  i i  i ii il
                    .01                 O.I
                      Particle Size,
    .001
 Fig.  6  -  Effect of  fuel on  particle  size  of  emissions
l.O
                          -407-

-------
  I01
      -    I   I  I I  I I 11
  I0e
  10?
  to4
  10s
                   I   I  I  I II I I I     I   I  I  INI];
                   JT9D  Engine - Take -Off
                    o  JET A  Fuel
                    •  PK  Fuel
 I02
   .001
i    i  i i i i i il	i   l   i  i i 11 il	l   iii
            .01                0.1
              Particle  Size,
1.0
Fig.  7  -  Effects  of fuel  on particle  size  of emissions
                           -408-

-------
•I
 0.

 <

 fc
      .10




      .08





      .06








      .04






      .03








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     .006








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              .01   .02  .03  .04   .05   .06   .07   .08   .09   .10   .11   .12   .13  .14



                                     Porticl* Silt,
               Fig. 8 -  Porticle shops foctor,  JT8D  engine, idle, JET A fuel.
                                      -409-

-------
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O6
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                                                                                                 Particle  Site, fj.ir<
                                                                        Fig.  9 - Particle shape factor, JT80 engine, take  off, JET A fuel

-------
      .10



      .06




      .06






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                                       Particle  Diameter,
                Fig. 10 •  Particle shape factor, JT9D  engine, idle, JET A fuel
                                      -411-

-------
Q.
X.
o
s.
I
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       .08




       .06






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              .Ol   .02  .03   .04   .05   .06   .07  .08   .09  .10   .11   .12   .13   .14

                                     Porticl* Size,  [Mm
                Fig.  II -  Particle shape factor, JT9D engine,  climb out, JET A
                                     -412-

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Idle                                                       iru i




  Fin. 12   1'articulatc Emissions, JT8D iMitaru-, .11:1  A  I IK I
 Idle                                                     { iinh-ou:




   Ki>i.  13  Piirt ii-ulati- Emissic^ns,  .ITW onciiK',  .IKT A  I tu 1
                           -413-

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            MEASUREMENT OF
FUGITIVE DUST EMISSIONS FROM HAUL ROADS

         Chatten Cowherd, Jr.
 Head, Air Quality Assessment Section

      Midwest Research Institute
         425 Volker Boulevard
     Kansas City, Missouri  64110
                  -415-

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                                  ABSTRACT
     This paper presents the results of a field testing program used to
develop emission factors for dust generated by heavy-duty truck traffic on
unpaved roads. Emission tests were performed on roads traveled by haul trucks
within an open pit taconite mine and within two integrated iron and steel
plants. Both chemically treated and untreated roads were tested. The basic
field measurements consisted of fugitive dust exposure profiles and particle
size distributions using vertically oriented arrays of isokinetic samplers
such that the total passage of airborne dust downwind of the test road seg-
ment could be determined.

     Test results a~e used to extend the applicability of the emission factor
equation previously enveloped for light- and medium-duty truck traffic on un-
paved roads associated with agriculture and industry. Correction terms which
appear in the equation account for the dependence of emissions on vehicle
weight, vehicle speed, and the fraction of suspendable fines (silt) in the
road surface material. Based on an expanded data set of 24 tests, including
vehicle weights up to 157 tons, the unmodified equation predicts measured
emission factors with a relative standard deviation of predictive error equal
to 26.1%. Test results suggest that inclusion of an additional correction
term involving number of wheels per vehicle would lower the predictive error.
Particle size data indicate that the fine particle (< 5 ,um) mass fraction of
the suspended particulate (< 30 ^m) emissions is approximately 35%, indepen-
dent of vehicle weight and road surface composition. Finally, limited testing
of chemical dust suppressants shows high initial control efficiency (exceed-
ing 90%) which decays with road usage.
                                   -416-

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                                INTRODUCTION
     Until recently,  the national effort to control industrial  sources  of  air
pollution has focused on emissions discharged from stacks,  ducts,  or flues
and carried to the point of discharge in confined flow streams.  Control strat-
egies have been based on the assumption that the primary air quality impact
of industrial operations results from the discharge of air  pollution from
conventional ducted sources.

     However, failure to achieve the air quality improvements anticipated
from the control of ducted emissions has spurred a detailed reexamination  of
the industrial air pollution problem. Evidence is mounting which indicates
that fugitive (nonducted) emissions contribute substantially to the air qual-
ity impact of industrial operations and, in certain industries, may exceed
the effects of stack emissions.

     Industrial sources of fugitive particulate emissions may be divided into
two classes--process sources and open dust sources. Process sources are fully
or partially enclosed operations from which emissions escape into the work-
place environment and/or the ambient air. Examples of process sources are
crushers, sintering machines, and metallurgical furnaces. Open dust sources
include those sources, such as raw material storage piles,  from which emis-
sions are generated by the forces of wind and machinery acting on exposed
aggregate materials.

     The travel of heavy vehicles on unpaved roads is the category of open
dust sources to which this paper is addressed. Truck traffic on haul roads is
a major source of fugitive particulate emissions associated with the surface
mining and processing of both metallic and nonmetallic minerals. Quantifica-
tion and characterization of dust emissions from haul roads are necessary in
order to assess control needs and to develop cost-effective control measures,
as necessary.
                     QUANTIFICATION OF OPEN DUST SOURCES
     Fugitive emissions from open dust sources are especially difficult to
characterize for the following reasons:

     1.  Emission rates have a high degree of temporal variability.

     2.  Emissions are discharged from a wide variety of source configura-
tions.

                                    -417-

-------
     3.  Emissions are comprised of a wide range of particle sizes including
coarse particles which deposit immediately adjacent to the source.

The si-berne for quantification of emission factors for open dust sources must
effectively deal with these complications.

     In 1972, Midwest Research Institute (MRI) (1) initiated a field testing
program to develop emission factors for four major categories of fugitive dust
sources:  unpaved roads, agricultural tilling, aggregate storage piles, and
heavy construction operations. Because the emission factors were to be appli-
cable on a national basis, an analysis of the physical principles of fugitive
dust generation was performed to ascertain the parameters which would cause
emissions to vary from one location to another. These parameters were found
to be grouped into three categories:

     1.  Measures of source activity or energy expended (for example, the
speed and weight of a vehicle traveling on an unpaved road).

     2.  Properties of the material being disturbed (for example, the content
of silt in the surface material on an unpaved road).

     3.  Climatic parameters (for example, number of precipitation-free days
per year on which emissions tend to be at a maximum).

By constructing the emission factors as mathematical equations with multipli-
cative correction terms, the factors became applicable to a range of source
conditions limited only by the extent of the program of experimental verifica-
tion.

     The use of the silt content as a measure of the dust generation potential
of a material acted on by the forces of wind and/or machinery was an important
step in extending the applicability of the emission factor equations to the
wide variety of aggregate materials of industrial importance. The upper size
limit of silt particles (75 ^m in diameter) is the smallest particle size for
which size analysis by dry sieving is practical;  and this particle size is
also a reasonable upper limit for particulates which can become airborne.
Analysis of atmospheric samples of fugitive dust indicates a consistency in
size distribution so that particles in specific size ranges exhibit fairly
constant mass ratios (1,2).

     In order to quantify source-specific emission factors, MRI developed the
"exposure profiling" technique (3), utilizing the isokinetic profiling concept
which is the basis for conventional source testing. Exposure profiling con-
sists of the direct measurement of the passage of airborne pollutant immedi-
ately downwind of the source by means of simultaneous multipoint sampling over
the effective cross section of the fugitive emissions plume. This technique
uses a mass-balance calculation scheme similar to Environmental Protection
                                     -418-

-------
Agency (EPA) Method 5 stack testing rather than requiring indirect  calculation
through the application of a generalized atmospheric dispersion model.

     Specifically, the exposure profiling method was used to  develop  emission
factors for:  (a) light-duty vehicular traffic on unpaved (dirt and gravel)
roads (1); (b) agricultural tilling utilizing a one-way disk  plow and a sweep-
type plow (1); (c) load-out of crushed limestone utilizing a  1.75 cu  yard
loader (1); and (d) vehicular traffic on paved urban roadways (2).  In order
to extend the applicability of the emissions factor equations to  sources in-
volving larger scale materials handling equipment, the following  sources were
tested at two integrated iron and steel plants (Test Series A and E)  (4):
(a) light-duty vehicular traffic on industrial unpaved roads; (b) heavy-duty
vehicular traffic on unpaved roads; (c) mixed vehicular traffic  on industrial
paved roads; (d) mobile stacking of lump iron ore; (e) mobile stacking of  pel-
letized iron ore; and (f) loadout of processed slag into a truck with a front-
end loader. All sources were tested under dry road conditions (i.e.,  daytime
periods at least 3 days subsequent to a precipitation occurrence) so  that
worst case emissions could be determined and used as a starting point for
projecting annual emissions.
               EXPANDED TESTING OF UNPAVED ROAD DUST EMISSIONS
     Figure 1 presents the emission factor equation previously developed for
dust entrainment by vehicles traveling on unpaved roads. Although this equa-
tion was found to have high predictive reliability for dry road conditions
(relative standard deviation of prediction error equal to 11.2% of the mean
measured value), the data base was limited to 11 tests. Moreover, only two
tests had been conducted for vehicle weights representative of haul trucks
used in mining and processing of minerals.

     Therefore, in order to strengthen the data base for the predictive emis-
sion factor equation, 16 additional tests of uncontrolled emissions from un-
paved roads were performed during the summer of 1978. Seven of these tests
(Series I) were conducted at an open pit taconite mine and the remaining
tests (Series F and G) at two integrated iron and steel plants. In addition,
five tests of traffic on roads treated with chemical dusts were performed.

     As in the previous tests, the primary tool for measuring fugitive dust
generated from vehicular traffic on unpaved roads was the MRI exposure pro-
filer. A vertical line grid of samplers (see Figure 2) was used for measure-
ment of dust emissions. At all times the MRI exposure profiler was posi-
tioned within 5 m of the downwind edge of the test road with air samplers
covering the effective cross section of the fugitive dust plume.

     Other equipment utilized in the testing included:  (a) cascade impactors
with cyclone preseparators for particle sizing, (b) high-volume air samplers
for determining upwind particulate concentrations, and  (c) recording wind

                                     -419-

-------
         EF=5.9
(IT) W(T)     (30?) |b/veh-mi
     Determined by profiling
     of emissions from light-
     duty vehicles on gravel
     and dirt roads under
     dry conditions.
               Estimated factor to
               account for mitigating
               effects of precipitation
               over period of one
               year.
          Determined by profiling of emissions from
          medium- and heavy-duty vehicles on gravel
          and dirt roads under dry conditions.
     where:  EF = suspended particulate emissions (Ib/veh-mi)
             s  = silt content of road surface material (%)
             S  = average vehicle speed (mph)
             W = average vehicle weight (tons)
             d  = dry days per year
Figure 1.  Predictive emission factor equation for vehicular
             traffic on unpaved roads•
                             -420-

-------
Figure 2.  MRI exposure profiler.
               -421-

-------
instruments utilized to determine mean wind speed and direction for adjusting
the MRI exposure profiler to isokinetic sampling conditions. A detailed de-
scription of the testing methodology is provided elsewhere (4).

     In order to determine the properties of road surface aggregate being
disturbed by the action of moving vehicles, representative samples of the
surface materials were obtained for analysis in the laboratory. Unpaved road
test segments were sampled by removing loose material (by means of broom
sweeping) from lateral strips of road surface extending across the traveled
portion. Moisture contents of samples were determined in the laboratory by
weight loss after oven drying at 110°C, and texture was determined by stan-
dard dry sieving techniques.

     In addition to the silt content of the road surface material, the emis-
sion factor equation (Figure 1) requires data on vehicle speed and weight,
averaged over the vehicle passes (approximately 50) accumulated during a
test. During each test, the speeds of vehicles passing the sampling station
were estimated by timing over a known travel distance. Estimates of vehicle
weights were obtained from plant personnel. In some tests, the vehicle passes
sampled were dominated by controlled test vehicles traveling at preselected
speeds.
                                TEST RESULTS
     The cumulative results of the field testing of vehicular traffic on un-
paved roads are provided in Table 1, which presents the emission factors for
suspended particulate (smaller than 30 /im in Stokes diameter) and for fine
particulate (smaller than 5 ^m in Stokes diameter), along with surface mate-
rial characteristics. The upper size limit of 30 fim for suspended particulate
is the approximate effective cutoff diameter for capture of fugitive dust by
a standard high-volume particulate sampler (based on a typical pirticle den-
sity of 2 to 2.5 g/cu cm) (1). Both Table 1 and Figure 3 compare actual emis-
sion factors with predicted values.

     Excluding run Nos. 1-1, 1-7, and 1-8 for the reasons given in the foot-
notes to Table 1, the relative standard deviation of prediction errors is
26.1% of the mean measured emission factor. For Test Series E and G, the emis-
sion factor equation consistently underpredicts the measured factors. This
appears to be due to the effect of 10- and 18-wheel trucks, which comprised
a substantial number of the passes in those tests. In all other test series,
the vehicle mix was dominated by four- and/or six-wheel vehicles.

     As indicated in Figure 4, there is no apparent relation between the
fraction of the emissions consisting of fine particles and the average
vehicle weight or the road surface composition. The average value is ap-
proximately 35% by weight.


                                    -422-

-------
TABLE 1.  PREDICTED VERSUS ACTUAL EMISSIONS—UNPAVED ROADS
Road surface
Emission factor^/
Test Silt Mean vehicle Mean vehicle
No. Type (%) speed (mph) weight (tons)
R-l ) Crushed 12 30
R-2 , limestone 13 30
S-3 ' 13 40
R-8 j 20 30
R-10> Dirt 5 40
R-13) 68 30
A-14 i Crushed 4.8 30
A-15 f slag 4.8 30
E-l ) 8.7 14
E-2 • Dirt 8.7 16
E-3 ' 8.7 16
F-21i Dirt/ 9.0 15
F-22 crushed 9.0 15
F-23' slag 9.0 15
F-24 | Dirt/slag 0.03 15
F-25 !' (Cohered 0.02 15
G-27 . 5.3 22
G-28 J 5.3 23
G-29 ( Crushed 5.3 24
C-30 / slag 4.3 25
G-31 1 4.3 29
3-32 ' 4.3 22
l-\ ) Crushed 4'7 «
•-1 1 rock and 4'7 «
1 glacial *'7 c
'-* till 4'7 15
1-5 4.7 15
1-7 | Crushed 6.1 13.5
1-8 f rock 5.1 13.5
(taconite/
waste)
I-? j Crushed 1.3 13
1-10 / rock l.il/ 13
I- 11 ' (TREX) 1.3 14
a/ Particles smaller than 30 jjm in diameter
b_/ Based on MRI emission factor.
c/ 100 x (predicted-actuaD/actual.
d/ Test Series 1-1 through 1-5 performed on
£/ Tests performed on day following 2 days
fj Assumed value.
£/ Equation not applicable.
3
3
3
3
3
3
70
70
34
34
23
3
3
4
3
3
17
12
9
14
3
30
b7
67
67
157
157
118
117


110
112
127



previously
lib/vehicle
Predicted^/
5.9
6.4
8.5
9.3
3.3
33
29
29
14
16
12
2.2
2. 2
2.8
if

7.7
6.1
5.0
6.0
4.5
9.8
13.9
13.9
13.9
27.4
27.4
25.5
25.3


.
£/
a/



inactive road.
roila)
Actual
6.0
6.8
7.9
8.1
3.9
32
27
29
17
16
19
3.2
1.7
2.4
0.071
0.39
13.7
9.0
6.8
11.6
6.6
21.8
, .d/
6.4—
9.9
20.3
24.3
30. r
15.1*.'
U.&S/


1.3
2.6
3.3




Percent
difference^'
_2
-6
8
21
-15
3
7
0
-17
0
-37
-31
29
17

-
-44
-32
-26
-48
-32
-55
117
40
-32
10
-11
53
73


.
_
-




Predicted
Actual
0.98
0.94
1.08
l.:i
0.85
1.03
1.07
1.00
0.32
1.00
0.63
0.69
1.29
1.17

-
0.-6
0.68
0.74
0.52
0.68
0.45
2.17
1.40
O.o8
1.10
0.89
1.38
1.73


—
-
—




of rain totaling 1.13 in.










                            -423-

-------
I
IS)
I
o
ON FACTOR
o
ACTUAL
o

                                                             1 Inch Rain on Previous Evening
                                        Tests on Inactive Road
                                                                                           TEST SITE - ROAD SURFACE MATERIAL
                                                                                         A Rural Kansas - Crushed Limestone
                                                                                         A Rural Kansas - Dirt
                                                                                         O Iron and Steel Plant -  Crushed Slag
                                                                                         t> Iron and Steel Plant -  Dirt/Crushed Slag
                                                                                         • Iron and Steel Plant -  Dirt
                                                                                         0 Taconite Mine - Crushed Rock (Taconite/Waste)
                                                                                         • Taconite Mine - Crushed Rock/Glacial Till
       1    1
                         1    1
                                   1    1
                                                                        1    1
                                                         1     1
                                                                       1    1
                                                                                    1    1
                                                                                                 J	I
                    10
                                                                       20                    30
                                                            PREDICTED EMISSION FACTOR (U(/VMT)
40
Figure 3.   Comparison  of  predicted  and  actual  emissions—untreated roads*

-------
I.UU

'5& °-80
Z
P= 0.60
(J
oe.
1 "-
6 £
r 2
^ 0.40
u
fe
0.
LU
Z 0.20
u_
0
ROAD SURFACE MATERIAL
A Crushed Limestone
A Dirt
D Crushed Rock (Taconite/Waste)
O Crushed Slag
• Dirt/Crushed Slag
• Crushed Rock/Glacial Till
-

> 0
* ° A * °
A O
~A • •
•
A
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
20
40         60          80         100
       AVERAGE VEHICLE WEIGHT (TONS)
120
140
160
    Figure 4.   Fine  particle fractions of TSP emissions.

-------
Analysis of parameters affecting the atmospheric transport of fugitive dust
indicates that only the portion smaller than about 5 urn in diameter will be
transported over distances greater than a few kilometers from the source (5).

     As stated above, limited testing of the effects of chemical dust sup-
pressants was also conducted. At the taconite mine site, TREX (ammonium
lignin sulfonate--a water soluble by-product of papermaking) was applied to
the waste rock aggregate comprising the surface of a haul road. A 20 to 25%
solution of TREX in water was sprayed on the road at a rate of 0.08 gal/sq
yard of road surface. The other chemical dust suppressant tested was
Coherex® (a petroleum-based emulsion), which was used to treat a dirt/slag
surfaced service road traveled by light- and medium-duty vehicles at an inte-
grated iron and steel plant. Coherex® was applied at 10% strength in water.

     Figure 5 shows a plot of measured dust control efficiency as a function
of the number of vehicle passes following application of the road dust sup-
pressant. Control efficiency was calculated by comparing controlled emissions
with uncontrolled emissions measured prior to road surface treatment. As
indicated, the effectiveness of road dust suppressants is initially high but
begins to decay with road usage. According to taconite mine personnel, the
binding effect of TREX can be partially restored by the addition of water to
the road surface. It should also be noted that the apparent performance of
Coherex®was negatively affected by tracking of material from the untreated
road surface connected to the 200-ft treated segment.

     With regard to the effects of natural mitigation of road dust emissions,
the final term in the emission factor equation for traffic on unpaved roads
(Figure 1) is used to reduce emissions from dry conditions to annual average
conditions. The simple assumption is made that emissions are negligible on
days with measurable precipitation and are at a maximum on the rest of the
days. Obviously, neither assumption is defendable alone; but there is a rea-
sonable balancing effect. On the one hand, 0.01 in. of rain would have a
negligible effect in reducing emissions on an otherwise dry, sunny day. On
the other hand, even on dry days, emissions during early morning hours are
reduced because of overnight condensation and upward migration of subsurface
moisture; and on cloudy, humid days, road surface material tends to retain
moisture. Further natural mitigation occurs because of snow cover and frozen
surface conditions. In any case, further experimentation is needed to verify
and/or refine this factor.
                                 CONCLUSIONS
     Based on an expanded data set of 24 tests, the MRI emission factor
equation for traffic-entrained dust from unpaved roads predicts measured
emission factors with a relative standard deviation of the prediction error
equal to 26.1% of the mean measured value. It appears that an additional ad-
justment term related to the average number of wheels per vehicle would

                                    -426-

-------
*>
ro
vj
                   100
                    90
                 G  so

                 z
                 UJ

                 u

                 t  70
                o
                on
                \-
                z
                o
                u
60
                    50
                   40
              VEHICLE TYPE
                      DUST SUPPRESSANT
O Haul Truck

A Light Duty Vehicles
Lignin Sulfonate


Coherex
                      100    120    140   160    180    200    220    240   260


                                     VEHICLE PASSES FOLLOWING TREATMENT
                                                              280    300
                              Figure 5.  Effectiveness of road dust suppressants.

-------
reduce the mean prediction error because there is a clear tendency to under-
predict measured emission factors when the road is traveled by a substantial
portion of 10- and/or 18-wheel vehicles rather than 4- and 6-wheel vehicles.

     Approximately 35% of measured road dust emissions in the suspended par-
ticulate size range (particles smaller than 30 /m in diameter) consist of fine
particles (particles smaller than 5 urn in diameter), which have the potential
for transport over distances greater than a few kilometers from the source*
This fraction appears to be independent of average vehicle weight and road
surface composition.

     Limited testing of chemical dust suppressants for industrial unpaved
roads indicates a high initial control efficiency (exceeding 90%), which de-
cays by more than 10% with the passage of 200 to 300 vehicles. Consistent with
the emission factor equation, the lowering of emissions is reflected by the
reduced silt content of the road surface material after the application of
chemical dust suppressants. Additional testing is needed to better quantify
the performance of road dust suppressants. Testing is also needed to verify
and/or refine the emission factor adjustment term which accounts for climatic
mitigation.
                               ACKNOWLEDGEMENT
     The work upon which this paper is based was performed pursuant to
Contract No. 68-02-2609, Task 3, with the U.S. Environmental Protection
Agency.
                   FACTORS FOR CONVERSION TO METRIC UNITS


                       1 kilogram   =2.2 Ib

                       1 kilometer   = 0.62  miles

                       1 metric ton =1.1 short tons
                                    -428-

-------
                                 REFERENCES
1.  G.  Cowherd*  Jr.,  K.  Axetell,  Jr.,  C« M. Guenther,  and G. Jutze,  "Devel-
      opment of  emission factors  for fugitive dust sources," Final Report,
      Midwest Research Institute  for U.S. Environmental Protection Agency,
      Publication No. EPA-450/3-74-037 (NTIS No. PB 238262/AS) (June 1974).

2.  C.  Cowherd,  Jr.,  C.  M. Maxwell, and D. W. Nelson,  'Quantification of
      Dust Entrainment from Paved Roadways," Final Report, Midwest Research
      Institute  for U.S. Environmental Protection Agency, Publication No.
      EPA-450/3-77-027 (July 1977).

3.  C. Cowherd,  Jr.,  "Measurement of fugitive partlculate," Second Symposium
      on Fugitive Emissions Measurement and Control, Houston, Texas, May  1977,
      Publication No. EPA-600/7-77-148  (December  1977).

4.  R. Bohn, T.  Cuscino, Jr., and C. Cowherd, Jr., "Fugitive emissions from
      integrated iron and steel plants," Final Report, Midwest Research
      Institute  for U.S. Environmental Protection Agency, Publication No.
      EPA-600/2-78-050 (March 1978).

5.  C. Cowherd,  Jr.,  and C. M. Guenther, "Development of a methodology and
      emission inventory for fugitive dust for the regional air pollution
      study," Final Report, Midwest Research Institute for U.S. Environmental
      Protection Agency, Publication No. EPA-450/3-76-003 (January 1976).
                                     -429-

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                 DEVELOPMENT OF MEASUREMENT METHODOLOGY
              FOR EVALUATING FUGITIVE PARTICIPATE EMISSIONS
Edward E.  Uthe, Charles E. Lapple, Clyde L. Wltham, and Robert L. Mancuso
                           SRI International
                      Menlo Park,  California  94025
                                  -431-

-------
                                    ABSTRACT
     A research project Is under way to develop and demonstrate a method for
evaluating fugitive particulate emissions from an industrial plant,  by measur-
ing the flow of total particulate pollution in the atmosphere downwind of it.
Using both surface sampling and remote-sensing techniques for sampling above
the surface level, the method is to be capable of measuring the spatial distri-
bution, absolute concentration, and velocity of the particulate cloud issuing
from the plant.

     The objective of the current study is to demonstrate the proposed method
under field conditions, but in circumstances that simplify and control the
variables of the general problem.  A field test was recently completed that
used an aerosol generator to emit a controlled aerosol stream into the atmo-
sphere from a point source with known particulate feed rates.  A mobile lidar
system was used to make a series of remote observations of the cross-plume
particulate distribution 300 to 500 m downwind of the source.

     Data presented show that the cross-plume integrated backscatter is respon-
sive to the particulate feed rate.  The problem of deriving an absolute mass
emission rate from such backscatter traverses of a plume is discussed.
                                     -432-

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                                 I  INTRODUCTION
     The total source strength of pollution emitted  by industrial  plants  is  the
aggregate of all diffuse and minor specific emissions as well as major  identi-
fiable point sources.  Therefore, for many plants,  the measurement of  individual
emissions from the multiplicity of sources is neither economical nor practical.

     The only feasible approach is to measure, as accurately as possible,  the
concentration throughout a cross section of the downwind "plume" of the com-
bined fugitive emissions, to integrate these, and,  from a measurement  of  the
integrated wind velocity through the plane of the cross section, to calculate
the pollutant mass flow.  For particulate fugitive emissions, any  deposition or
transformation in the intervening distance must also be considered, to derive
an estimate of the total source strength.

     The problems of accomplishing such measurements with existing technology
are many.  Specifically, with in-situ samplers it is virtually impossible to
characterize adequately the concentration of particles throughout  the  total
cross section of the plume, or to relate any measurements made to  the  total
envelope of the plume, or to determine its extent.  This is especially the case
above the surface, because of the extended and variable nature of  the  multiple
sources of fugitive emissions.

     Lidar  (laser radar) observation fulfills, as no other method does, the
requirement for delineating the spatial distribution of elevated particulate
pollution plumes, and also for readily distinguishing between background pol-
lution and pollution from the plant being studied.  While there are limitations
and difficulties in using lidar backscatter measurements for determining abso-
lute particulate concentrations, it is possible to evaluate, with useful ac-
curacy, the near-instantaneous mass distribution of particulate material within
a selected cross section or envelope.  It is  thus possible to derive series of
such cross sections  in  time, and to relate these to a measurement of mean wind
velocity, to derive an  estimate of mass flow  and hence of source strength.
(Several lidar techniques have been demonstrated for wind measurement, but
these are not currently at an operational stage and simpler, more conventional
methods of wind measurement are  still indicated.)  Finally,  eye safety from
laser systems used over industrial sites must be considered.   In principle,
however, it is apparent that lidar offers a unique potential for eventually
providing quantitative  measurement of fugitive particulate emissions.

     This paper presents results  from an  initial attempt  to  demonstrate, using
presently available  research equipment,  the  capabilities  of  lidar  for measuring
particulate fugitive emissions,  and  recommends several  research areas  requiring
further  consideration  to fully  exploit  the  lidar  technique  for this purpose.
                                      -433-

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                            II  THE LIDAR TECHNIQUE


     Lidar  (Light Detection and Ranging) uses laser energy in radar fashion to
effectively observe remote atmospheric constituents.  The lidar system being
used to develop methodologies for fugitive dust measurement is SRI Interna-
tional's Mark IX mobile system, designed for use with atmospheric research
programs.  Figure 1 presents views of the lidar system, a block diagram, and
a list of specifications.  The lidar is installed within an 18-ft van complete
with real-time data processing and display capabilities as well as with power-
generating equipment, enabling operation at any site.

     Figure 2 is an example of an intensity-modulated TV display depicting the
cross-plume aerosol structure observed by scanning the lidar in elevation.  The
brightness of this display is proportional to the logarithm of the backscattered
light detected by the lidar system.  Clearly, lidar can be used to map relative
aerosol density distributions over remote distances.  Computer-generated
vertical-concentration profiles are plotted on the cross section for locations
indicated by the cursor marks drawn above the plume return.  Similarly, the
backscattered data can be spatially integrated to determine a relative cross-
plume density.  Light that is elastically backscattered from suspended atmo-
spheric particulate matter, as a function of pulse-transmission time, is quan-
titatively related to (clear air and plume) optical parameters along the ob-
served path according to the lidar (radar) equation


                               P = K E 0 R~2 T2                              (1)

where

         P  =  received power from a scattering volume  defined by  the  laser  pulse

         K  =  lidar calibration constant

         E  =  transmitted power

         8  =  backscatter coefficient of  the  scattering volume

         R  »  range from lidar of the scattering volume

         T  =  transmission  to the scattering  volume

For relatively clear air, the attenuation term can normally be ignored (T2 « 1)
and P provides information on the distribution of particulate material in
the atmosphere, as shown in Figure 2.   However,  the evaluation of physical-
density terms (such as mass concentration) requires relating the optical param-
eter 3 to the density.   Unfortunately,  backseatter-to-concentration ratios are
dependent on the distributions of particle size,  composition,  and shape.  Before
these factors, and the ways in which they can limit the accuracy of quantitative
evaluations of plume density,  can be considered,  the lidar observations must be
shown to respond in a predictable manner to increases of plume density for a
given aerosol type.   An experimental field program using presently available
research equipment has been conducted for this purpose.  The design of the field
program is  discussed below, followed by some of the preliminary results.


                                     -434-

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    MARK IX LIOAR VAN
                             (b)
                     ANALOG DATA AND FIRE
                     CONTROL ELECTRONICS
(c)
DIGITAL DATA ELECTRONICS
AND TV DISPLAY
                      EXTERIOR AND INTERIOR VIEWS OF THE LIDAR VAN
    BLOCK DIAGRAM OF THE LIDAR SYSTEM
                                              LIDAR SPECIFICATIONS
                                             TRANSMITTER
                                             6943A Wavelength
                                             0.5 mrad Beamwidth
                                             1.0 J Pulse Energy
                                             30 ns Pulse Length
                                             60 ppm Maximum PRF
                                              RECEIVER
                                              6 inch Newtonian
                                              1 to 5 mrad Field of View
                                              5A Predetection Filter
                                              RCA 7265 PMT Detector
                                              4-decade, 35-MHz Log-
                                              arithmic Amplifier, Inverse-
                                              range-squared or step-
                                              function PMT modulation.
                                                        DATA SYSTEMS
                                                        Analog video disc recording
                                                        (4.5 MHz) with A-scopeand
                                                        Z-scope real -time displays.
                                                        Digital magnetic tape (data
                                                        and programs) recording
                                                        (25 MHz) with computer
                                                        processing and real-time TV
                                                        display (512 x 256 x 4 bit)
                                                        of processed data.
                                                        MOUNT
                                                        Automatic azimuth and elevation
                                                        fire and scan with 0.1 minimum
                                                        resolution. Automatic reset.
                                                        Mechanical safety stops.
          FIGURE 1   SRI  INTERNATIONAL'S MARK IX MOBILE LIDAR SYSTEM
     Ul
     5
     CO
     H
     o
     UJ
     I
FIGURE  2
                 HORIZONTAL DISTANCE FROM LIDAR
EXAMPLE  OF COMPUTER-GENERATED PROFILES OF  VERTICAL PLUME  DENSITY
Lidar is located at lower  left  corner.   The height and distance
scale is 75 m/div.   Vertical concentrations of the plume  (rela-
tive to  clear air,  with a  scale of 10  dB/div)  are plotted at  the
lower left and the  horizontal position associated with each
profile  is plotted  in  the  upper right.
                                            -435-

-------
                                Ill  FIELD STUDY
     The experiments were conducted under actual field conditions but simplified
to the extent that the observed particulate plume would have better-known prop-
erties than could be expected in the general case.  Dust was emitted into the
atmosphere in a controlled manner.  The intent was to show that observed back-
scatter spatially integrated across the aerosol plume downwind of the source is
well correlated with the source strength.  In addition to lidar observations,
conventional wind measurements were made to determine downward dilution of the
particulate plume; near-surface particulate sampling was conducted to investi-
gate possible approaches for measuring actual fugitive emissions with unknown
particulate properties.

     An aerosol source was designed and constructed to generate a point source
of dust by feeding a fine powder of known properties into a sonic-velocity air
stream pointing downwind.  The source is capable of emitting aerosols at three
levels—1, 3, and 10 m above ground level.  The powder is fed at a uniform rate
by means of a grooved-disk feeder of proprietary design.  The disk rotation rate
can be continuously varied to control the particle feed rate.  A compressed air
stream of 40 ft3/min at 52 psi was used to disperse the dust metered out by the
feeder.

     For the dust, Min-U-Sil (a commercially available* ground silica) was
chosen because (1) the particles are predominantly below 5 um in diameter;
(2) the material is available in quantity; and (3) the dust is a realisic
example of material encountered in practice.  Figure 3 shows an aerosol plume
generated by dust emissions from the bottom and top nozzles of the generator.

     The Mark IX lidar van was positioned 300 to 500 m from the source so that
the laser beam would intersect the plume perpendicularly at a downwind distance
of about 300 to 500 m.  The lidar was scanned in elevation to observe the cross-
plume aerosol distribution, similar to that shown in Figure 2.  An anemometer
was installed on the Mark IX lidar van and its signal output was input to the
lidar digital system so that both wind speed and direction were sampled for
each lidar observation (firing).  In addition, the output of an integrating
nephelometer was similarly sampled.  These data and the digital record of the
backscatter signature were stored on magnetic tape for use during the data
analysis program.

     An initial data collection program was conducted during May 1978 and a
second data collection period using slightly improved experimental techniques
was conducted in September 1978.  For each experimental run, aerosol plumes
were generated at three different particulate feed rates.  For some meteorolog-
ical conditions, the cross-plume aerosol density at a given distance from the
source was quite variable.  Therefore, a series of about ten vertical lidar
cross sections were collected for each particulate feed rate, so that the value
of the time-integrated cross-plume backscatter could be determined.  Preliminary
results obtained from the field program are presented in the next section.
 Pennsylvania Glass Sand Corp., Pittsburgh, PA.

                                      -436-

-------
FIGURE 3  CONTROLLED DUST PLUMES GENERATED TO REPRESENT FUGITIVE EMISSION
          SOURCES
          (a)  Emission 1 m above surface
          (b)  Emission 10 m above surface
                                   -437-

-------
                             IV   PRELIMINARY RESULTS
      The  range-dependent backscatter  signatures were collected while the lidar
 was  scanned  in  elevation,  to observe  the  total cross-plume aerosol  (Figure 2).
 While the resulting data can readily  be integrated  in polar coordinate form,
 an objective method was applied to evaluate an array of backscatter values in
 Cartesian coordinates.  The advantage of  an x-y grid is that the values can
 be displayed with commonly used computer  techniques, to facilitate  indentifica-
 tion of plume and clear air regions.  The integrated cross-plume backscatter
 was  determined  from the expression
/
                     'p dA -<*  +     dA '


     where 3  = plume backscatter coefficient  [see Equation (1)]

           3  = clear-air backscatter coefficient
            c

           A  - area that includes all plume particulates

           A' = area that excludes plume particulates.

The first term represents plume and clear-air backscatter integrated over an
area of the vertical cross section containing the plume, and the second term
is an estimate of the clear-air backscatter integrated over the same area.

     The primary objective of this study was to demonstrate experimentally that
the integrated cross-plume backscatter responds in a linear manner to changes
in the total mass concentration of particulate material released into the
atmosphere.

     The total rate of fugitive dust emission, w, can be calculated from the
distribution of particulate concentration in a given vertical plane downwind
of the source by
                                W=/CU
                      sinG  dA                            (3)
where c is the concentration in the area segment dA at which the wind velocity
is u and is oriented at an angle 0 to the vertical plane.  Assuming c is pro-
portional to the lidar backscatter coefficient (c = K3), and assuming a constant
wind speed and direction at all parts of the vertical plane observed by the
lidar, we have


                             w = K u sinG  / $  dA                           (4)


     For each observation (vertical cross section), the backscatter records
were processed in terms of an array of backscatter values for identifying appro-
priate clear-air and plume regions, to evaluate Equation (2).  The integrated


                                      -438-

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cross-plume backscatter values were computed and  statistically  analyzed  for  the
average and standard deviation for each set of  observations made  at  a  fixed
particulate feed rate.

     Figure 4(a) presents experimental results  for two  observational periods,
using the integrated cross-plume backscatter as an estimate of  the rate  of
fugitive dust emission.  For each case, three emission  rates  were used,  and
for each rate, from 8 to 20 vertical cross sections were made.  The  data show
that the integrated backscatter generally increases linearly  with the  particu-
late emission rate.  However, relatively large scatter  of the data points
occur—i.e., large standard deviations.  This can be explained  partly  on the
basis of variable wind conditions, which were ignored in this estimate of
emission rate.

     Figure 4(b) presents the data shown in Figure 4(a) after wind-speed (but  not
direction) corrections were applied; these were based on anemometer  measurements
made at the lidar site during the data-collection period.  The  wind  corrections
improve the linear relationship between the lidar observations  and the particu-
late feed rates (especially for the second case).  However,  the standard devia-
tions remain about the same.  This variability is thought to  result  partly from
small-scale, uncontrolled variations in the particle feed rates and  turbulent
conditions resulting in a nonuniform aerosol concentration downwind  of the
source.  Both these factors were visually observed to cause backscatter varia-
tions, but an estimate of their relative importance could not be made.  Never-
theless, these data illustrate that the lidar technique provides  a downwind
measurement that responds in a predictable  (linear) manner to the total par-
ticulate emission rate as evaluated from feeder calibration data.
                     V  ABSOLUTE PLUME DENSITY MEASUREMENTS
     The data presented in the previous section of this paper indicate that for
a given type of particulate material, the lidar can be calibrated to provide
an absolute measurement of aerosol density of a downwind pollution plume.  How-
ever, fugitive dust emissions from a multiplicity of source types may consist
of a heterogeneous complex of particle size, shape, and composition distribu-
tions.  The lidar wavelength(s) or observational techniques must be carefully
selected to minimize errors of density measurement associated with uncertainties
of particle characteristics.

     Earlier experiments used a large-scale chamber that was especially designed
for making remote lidar observations of generated aerosols of known particle
size, shape, composition, and concentration (Lapple and Uthe, 1976).  Observa-
tions of aerosols generated from fly-ash particulates of different size cate-
gories showed that the backscatter-to-mass concentration ratio  is less dependent
on particle size at a lidar wavelength of 1.06 urn than at 0.7 urn.  Recent  trans-
missometer experiments  (Uthe, 1978) have shown that extinction  measurements  in
a wavelength interval of 3 to 4 ym provide a good indicator of  aerosol volume
concentration regardless of particle size, shape, or composition  (for the  range
of typical pollutants).  While backscatter certainly is sensitive to changes in
particle shape or composition, measurements in the  3- to 4-ym region may result
in a higher correlation between backscatter and aerosol mass concentration when


                                      -439-

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40
30
20

10
8
6
4
n
\ 2
i
i
E
c
]
u
I 40
5 30
|
i 20
10
8
6
4
2
1
1 1 1 1 1 1 1 1
DUST RELEASE
— 1 M ABOVE SURFACE ~
iO = ONE STANDARD
DEVIATION
k
— T X
I ft*
- / J

)8
—
—
- - la —
X 1
T X
X -
V ?13 = Number of observations
16 MAY 1978
1 T 1 1 1 1 1 1 1









_ 1 1 1 1 1 II 1 1
DUST RELEASE
-10 M ABOVE SURFACE ~
X* 10 -
4g)\Q
/ -L - 10
— ^/ —2
- X O 20 —
— / —
X
22 SEP 1978
1 1 1 1 1 1 I 1 1
2 468 10 20 30 2 468 10 2030
EMISSION RATE (FEEDER) - kg/hr
(a) LIDAR ESTIMATE BASED ON INTEGRATED CROSS-PLUME BACKSCATTER, //? dA
1 1 1 1 1 1 • 1 I
DUST RELEASE
~ 1 M ABOVE SURFACE
A
T X
— tl'
E x
T xX
-+ 10 —
)8
__
—
•-10 ~
\ / • -\
V13
-xT -
16 MAY 1978
I I I I I I I I I
2 4 6 8 10 20 30









1 I 1 1 1 1 | 1 1
DUST RELEASE
~ 10 M ABOVE SURFACE ~
~~ -r + 10 ""
^r10.
_ /L - «_
	 > ~
- X!)^ ~
X 1
_ X
T x
/ / «
_ >fl9
22 SEP 1978
1 1 1 1 1 III 1 1
2 4 6 8 10 20 30
FIGURE 4
                     EMISSION RATE (FEEDER) - kg/hr

     (b)  LIDAR ESTIMATE BASED ON PRODUCT OF INTEGRATED CROSS-PLUME
         BACKSCATTER, AND MEAN WIND SPEED, u/0 dA

PARTICULATE EMISSION RATE EVALUATED FROM LIDAR PLOTTED AS A FUNCTION
OF EMISSION RATE EVALUATED FROM PARTICLE FEEDER
Dashed  line is best-fit linear fetation.
                                       -440-

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 the particle  size  is variable.  Clearly, additional experiments are needed to
 define  optimum wavelength regions and  to establish uncertainties in plume
 density measurements because of unknown particle characteristics.

     A downwind in-situ measurement  of the backscatter-to-mass concentration
ratio may provide the basis for converting backscatter observations  to  fugitive
particulate concentrations.   One possible approach is  to sample the  aerosol
mass concentration at a location near the path of  the  laser beam.  For  example,
a filter sample could be taken over an extended time period while repetitive
lidar observations are made of nearly the same atmospheric volume.   The time-
integrated backscatter from this volume and the mass concentration measurement
would provide an estimate of the backscatter-to-mass concentration ratio re-
quired to quantitatively evaluate the integrated cross-plume density from the
lidar-observed, above-surface backscatter distributions.  While this method
may provide the necessary information to interpret backscatter data  quantita-
tively in terms of aerosol density,  an especially designed instrument for mea-
suring the backscatter-to-mass concentration ratio is  desired.  Of course, if
an observational technique can be developed to reduce to within acceptable
standards the dependence of the density measurement on the uncertainties of
particle characteristics, these supporting observations will not be necessary.
                      VI  CONCLUSIONS AND RECOMMENDATIONS
     Using an existing mobile lidar system, a field program has been conducted
to demonstrate that for a single particulate type, the cross-plume Integrated
backscatter is a good indicator of source strength of particulate emissions.
The positive results obtained from this first field program encourage the
further development of this methodology for measuring fugitive dust concen-
trat ions.

     We plan to test the lidar technique using sources of different particle
size, shape, and composition distributions.  For example, the next test may be
of the emissions from a liquid-particulate generator capable of producing both
black and white oil smokes.  Other areas to be investigated include:

     •  Selection  of optimum wavelength(s) regions to minimize mass measurement
        errors associated with uncertainties in particle size, shape, and com-
        position distributions.
     •  Development of an eye-safe lidar technique.

     •  Evaluation of wind-measuring  lidar techniques to evaluate actual flow
        of observed pollutants.

     •  Development of an instrument  to measure backscatter-to-mass concentra-
        tion in situ.

     •  Further experimental evaluations of proposed methodologies using sources
        of known particulate properties.
                                      -441-

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                                ACKNOWLEDGMENT


     SRI International's work was sponsored under EPA Contract No. 68-02-2752,
The authors are grateful to William D. Conner of EPA for his part in the
program and his review of the manuscript.
                                   REFERENCES
Lapple, C.  E., and E. E.  Uthe,  1976:   "Remote Sensing of Particulate Stack
     Emissions," AICHE Symposium Series,  Vol. 72,  No. 156,  pp.  181-202.

Uthe, E. E., 1978:  "Remote Sensing of Aerosol Properties Using Lidar (Laser
     Radar) Techniques,"  Proceedings of SPIE Seminar on Optical Properties of
     the Atmosphere,  Washington, D.C., 30 March 1978.
                                     -442-

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         DEVELOPMENT OF A FUGITIVE
         ASSESSMENT SAMPLING TRAIN
   FOR PARTICIPATE AND ORGANIC EMISSIONS
Henry J. Kolnsberg, Senior Project Manager

 Roland L. Severance, Principal Engineer
TRC-THE RESEARCH CORPORATION OF NEW ENGLAND
          125 Silas Deane Highway
       Wethersfield, Connecticut 06093
                     -443-

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                                    Abstract
     The measurement of fugitive emissions from sources that preclude the cap-
ture of emissions before their diffusion into the ambient atmosphere poses some
unique problems.  Devices designed to obtain ambient samples for area studies
generally do not provide samples of particulate matter large enough for meaning-
ful quantification and qualification analyses in a reasonable sampling period,
and are usually completely non-directional in their sampling.

     This paper describes a program for the development of a prototype portable
Fugitive Assessment Sampling Train (FAST) designed to obtain a 500 milligram
particulate matter sample in an 8 hour sampling period downwind of most indus-
trial sources.  The development of the design criteria, establishment of oper-
ating parameters, selection and design of hardware components, fabrication and
initial testing of the FAST are described in detail, and the program for the
qualification testing of the completed unit is outlined.
                                     -444-

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     A considerable portion of the air-polluting particulate matter and
organic vapor emissions from industrial and energy-related processes is
generated by sources that do not permit the capture of their emissions for
measurement purposes before their diffusion into the ambient atmosphere.
Obtaining samples of such fugitive emissions of sufficient size to perform
statistically significant analyses of their concentration, particle size
distribution, physical characteristics, chemical composition or biological
activity presents a problem not readily solved using existing devices and
traditional sampling techniques.

     Standard high volume samplers, for example, can provide some information
about the average particulate matter concentration at a sampling site over a
long sampling period, but do not provide samples large enough for other than
total mass determinations.  Cascade impactors can provide particle size
distribution information for a relatively small sample and cyclone separators
can collect a fair-sized particulate matter sample in a few size ranges to
provide essentially the same information.  Grab sampling of gases or vapors
for subsequent gas-chromatographic analysis can provide data on the chemical
composition and approximate or relative concentration of these emissions, but
is subject to the influence of interaction between emissions or aging of the
samples.  No single sampler exists that can collect a particulate matter sample
large enough or a vapor sample stable enough to provide information in all
areas.

     This paper describes the progress made to date in the development of a
Fugitive Assessment Sampling Train (FAST) designed to fill the requirements for
a sampler capable of providing a large sample of particulate matter emissions
from the atmosphere in a relatively short sampling period.  A smaller organic
vapor sample is obtained from the sampled stream.

     The development effort was conducted by TRC-THE RESEARCH CORPORATION of
New England under a contract  (68-02-2133) with  the Process Measurements Branch
of the United States Environmental Protection Agency's Industrial  Environmental
Research Laboratory at Research Triangle Park,  North  Carolina.  Discussions
between TRC personnel and  the EPA Project Officers, Dr. Robert M.  Statnick and
D. Bruce Harris, resulted  in a  target  design specification  for an  ideal
sampling train as the development  starting  point.  This ideal sampler was
described as being able  to  obtain, from  the ambient air in  the vicinity of an
industrial fugitive  emissions source,  a  500 milligram sample of suspended
particulate matter and a  similar-sized sample of organic  vapors in an eight-
hour sampling period.  The particulate matter  sample  would  be separated into
respirable  (smaller  than  3 micrometer) and  non-respirable (larger  than 3
micrometer)  fractions.   The sample sizes were  selected to correspond  to  the
then-considered minimum  for complete analysis  including bio-assay.   The sampler
was also to be self-contained and  portable;  it  would  require minimum power and,
using commercially  available components  wherever possible,  cost less  than
$10,000  to  fabricate in  the prototype  version.

     An  extensive computerized  literature  search and  review was  conducted in
the hope of  obtaining  sufficient  information on ambient  concentrations of
industrial  fugitive emissions as  particulate matter and  organic vapors to
prepare  a  realistic  system design specification for the  FAST.  While this
search  and  review  revealed almost no data  on ambient concentrations, it  did
provide  a wealth of  information on emission rates  from a wide variety of

                                       -445-

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industrial processes.  A series of calculations based on the atmospheric
diffusion equations in Turner's Workbook (1) for a range of atmospheric,
topological and wind conditions was then performed to relate the published
emission rates to ambient concentrations.  These calculations indicated that
an ambient concentration of 200 micrograms per cubic meter can be found within
100 to 500 meters of sources emitting between 0.6 and 23 kilograms per hour—
a range covering about 90 percent of the industrial sources for which data is
available.

     This 200 microgram per cubic meter concentration was used to determine the
sampling rate required to obtain a 500 milligram sample in an eight-hour period
of 5.2 cubic meters per minute (184 CFM) as the initial system design parameter.
A Roots lobe-type vacuum blower, capable of moving the required volume of air
against a pressure drop of about 10 cm Hg, was selected as the particulate
sampling prime mover.  A system of drive belts and pulleys was utilized to
operate the blower at the required 3800 RPM from a three horsepower drive
motor.  The drive system also provides enough flexibility to adjust the speed
and the sampling rate up to about 20% if required.

     To provide for the separation of the particulate matter sample into
respirable and non-respirable fractions, an Air Correction Design 6UP Sanitary
Cyclone Separator was selected.  Its design capacity of 6.3 cubic meters per
minute (222 CFM) provides a DSQ at about 2 micrometers at a pressure drop of
about 0.6 cm Hg.  The cyclone was selected as preferable to filter- or
impactor-type collectors since the sample is removed from the sampling stream
and minimizes the degradation in sampling rate or effectiveness caused by the
deposition of particulate matter on flow-through filters or impactor plates.

     Consultations with Mr. Kenneth Cushing of the Southern Research Institute,
under contract to the Process Measurements Branch in the area of particulate
matter sampling, indicated that Reeves-Angel 934AH glass fiber filter material
would be about 99.95% effective in collecting the fraction of the particulate
matter sample down to about 0.3 micrometers passed through the cyclone.  A
circular format was selected for the filter material to provide the most even
distribution of the sample on the filter surface and minimize the pressure drop
buildup.   A circular filter holder was designed to accommodate a 929 square
centimeter (1 square foot) filter, limiting the pressure drop across the
unloaded filter to 3.7 cm Hg.  A louvered inlet section was also designed to
reject particles larger than 100 micrometers to complete the particulate matter
sampling section of the train.

     To provide stable samples of airborne organic vapor emissions, it was
decided to utilize an adsorbent resin in a removable canister that could be
easily transported from the sampling site to a laboratory for extraction and
analysis of the sample.  Dr. Philip Levins of Arthur D. Little, Inc., under
contract to the Process Measurements Branch in the organics sampling area,
provided consultation to TRC on the resin.  The best available resin, XAD-2
which is almost 100% effective in retaining organic vapors C6 and higher,
was determined to require a canister containing about 75 kilograms to provide
a 500 milligram sample.  This was prohibitive from the standpoints of size and
cost, and the design criterion was revised to obtain the minimum sample
required for a Level 1 assessment of 14 milligrams.  This sample size requires
only 2.1 kilograms of resin and a sampling rate of only 0.14 cubic meters per
minute (5 CFM).  A canister was designed and an oil-less Cast vacuum pump

                                     -446-

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selected to draw the sampling  stream from the main stream after the
particulate matter  is removed.

     The system design was  reviewed and approved and procurement and
fabrication efforts started.   At this time, the EPA's Health Effects Research
Laboratory suggested that an additional size fraction of the particulate
matter sample be included to help in the assessment of the inhalable  (less
than 15 micrometer) portion of the emissions.  It was decided to add a  battery
of six single stage Sierra  Instrument impactors to the system to effect this
additional fractionation between the inlet and the cyclone.  These  impactors
were designed to provide a  095 for 15 micrometer particles at the system
sampling rate with  a pressure  drop of only 0.05 cm Hg, and could therefore be
added without affecting  the system design.

     The final system design  is shown schematically in Figure 1.  Design flow
rates and pressure  drops  for  each system element are shown enclosed in
brackets.  Samples  retained by each element are shown in parentheses.
  [184 CFM]

 UOOX>100/j>
[0.05 CM HI]
                                        FILTER
                                          AP
                                                      VACUUM
                                                       GAGE
                                                                        EXHAUST
                       FILTER
                     noox>o.3//i
                     [3.7 CM H,]
                            CYCLONE
                            !50X>2/i)
                           [0.8  CM H,]
                                                         MAIN  VACUUM
                                                           BLOWER
XAO-2  MODULE
 HOOX>C4)
                                                                        [179 CFM]
                                                TRAP
                                               OUTLET
                                                 T.C.
                                          FILTER
            VACUUM
             PUMP  [5 CFM]
                   FIGURE  1 - FUGITIVE ASSESSMENT SAMPLING TRAIN
                               DESIGN  OPERATING CONDITIONS
      The procured and fabricated  elements of the prototype system were  then
 loosely packaged onto a space  frame about 75 cm (2.5 feet) square by  183 cm
 (6 feet) high to allow easy access to the elements during development testing.
 The main sampling blower and the  organic vapor sampling pump'were separately
 mounted to improve the system's portability and permit the location of  the
                                      -447-

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blower and pump exhausts away from the sampling Inlet.  The packages are shown
in Figure 2 as they appeared for the initial operational tests.
                                   FIGURE  2

                   PROTOTYPE  FAST  SYSTEM  INITIAL  ASSEMBLY
     After a successful operational test and a few modifications  to  the  system
were completed at TRC, the FAST was shipped to the Southern Research Insti-
tute's laboratory for calibration testing of the particulate sampling section.
Tests were run by Southern using monodisperse ammonium fluorescein aerosols
provided by their vibrating orifice aerosol generator at 3, 10 and 15 micro-
meters.  The test results for the cyclone, shown in Figure 3 as points plotted
on the manufacturer's design curve, are in very good agreement.   The test  re-
sults for the impactor, also shown in Figure 3, indicate good agreement  with
the design curve for smaller particles but are considerably lower than expected
for the 15 micrometer particles of major concern.
                                     -448-

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     X

     >^
         IOO
          «0
          •0
          7O
     o
     UJ
     a
     CJ
          so
          40
          3O
          JO
           10
               I  I  I  I  I I I
     I    I
                           GLASS FIBER
                           SUBSTRATES
                 IMPACTOR ---
                 CYCLONE ----
                CYCLONE DESIGN  CURVE
                                                    .	 IMPACTOR DESI6R
                                                 f '         CURVE
                '   »   I  M II
         X
»•— r* i  i  MIM
                .4  .J  .« .1 .« .VIA
                                               4  S  6  7 • * 10
                                                                     2O
                            PARTICLE DIAMETER MICROMETERS

       FIGURE 3: COLLECTION EFFICIENCY VERSUS PARTICLE DIAMETER FOR  THE FUGITIVE
                ASSESSMENT SAMPLING TRAIN PRE-SEPERATOR IMPACTOR AND CYCLONE

     Since it was felt that this discrepancy was  caused by bouncing  of the
larger particles off the  glass fiber  substrate used  in  the impactors, a test
was run using a grease substrate in an  attempt to reduce the bounce.  This
resulted in a slight improvement in performance,  but not to a level  considered
satisfactory for further  development.   A joint effort by TRC and Southern
Research has been initiated to design and fabricate  an  elutriator to replace
the impactor as the 15 micrometer  fractionator.  It  is  expected that the
elutriator, envisioned as a battery of  parallel settling chambers, will replace
and perform the functions of  both  the inlet louvers  and the impactors.

     A field test of the  FAST has  been  planned for the  near future at a coke
oven battery, where the system will be  tested  simultaneously with two Battelle
mega-vol samplers and a standard hi-vol sampler in the  measurement of emissions
from coke pushing operations. This test, to be run prior to the fabrication
and installation of the elutriator, should provide sufficient data for contin-
ued development of the cyclone and filter sections as well as an initial
indication of  the effectiveness  of the  adsorbent canister train design.

     It  is expected that  the  FAST  will  require some modifications and a repeat
of the calibration and field  testing  cycle after the addition of  the elutriator.
Verification tests of  the total  system will be performed  after  the modifica-
tions and additions have  been completed and an operating  procedures  manual  will
be prepared and published for the final version.
                                       -449-

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     The efforts to date in the development of this Fugitive Assessment
Sampling Train have been quite successful and encouraging.  The completion of
the planned effort will provide a useful tool for rapid, reasonable assess-
ments of fugitive particulate matter and organic vapors from a wide variety of
industrial sources.
                                   Reference

(1)  Turner,  D.  Bruce.   Workbook of Atmospheric Dispersion Estimates.   Public
     Health Service Publication No. 999-AP-26,  U.S.  Department of Health,  Edu-
     cation and Welfare, Cincinnati, Ohio.   Revised  1969.   84 pp.
                                    -450-

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                                TECHNICAL REPORT DATA
                         (Please read Instructions on the reverse before completing)
 . REPORT NO. ,
 EPA-600/7-79-182
                           2.
           3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Third Symposium on Fugitive Emissions Measurement
 and Control (October 1978, San Francisco, CA)
           6. REPORT DATE
           August 1979
           6. PERFORMING ORGANIZATION CODE
7. AUTMOR(S)
                                                      8. PERFORMING ORGANIZATION REPORT NO.
J. King, Compiler
9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                      1O. PROGRAM ELEMENT NO.
TRC--The Research Corporation of New England
125 Silas Deane Highway
Wethersfield,  Connecticut 06109
            INE623
            11. CONTRACT/GRANT NO.

            68-02-2615,  Task 201
12. SPONSORING AGENCY NAME AND ADDRESS
 EPA, Office of Research and Development
 Industrial Environmental Research Laboratory
 Research Triangle Park, NC 27711
            13. TYPE OF REPORT AND PERIOD COVERED
            Proceedings; 10/23-25/78
            14. SPONSORING AGENCY CODE
             EPA/600/13
15. SUPPLEMENTARY NOTES JJERL-RTP prOJCCt OfflCCr Ifi D.
 541-2557.
        Bruce Harris, Mail Drop 62,  919/
16. ABSTRACT
 The proceedings are a compilation of technical papers prepared for presentation
 at the Third Symposium on Fugitive Emissions, October 23-25, 1978, at San Fran-
 cisco,  CA.  The papers discuss the scope and impact of fugitive emissions (non-
 point sources) and present techniques which have been used to measure the emis-
 sions.  Fugitive emission control technologies are also discussed.
17.
                             KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
                                          b.IDENTIFIERS/OPEN ENDED TERMS
                           cos AT I Field/Group
 Pollution
 Measurement
 Processing
 Leakage
Pollution Control
Stationary Sources
Fugitive Emissions
Non-point Sources
13B
14 B
13H
18. DISTRIBUTION STATEMENT
 Release to Public
19. SECURITY CLASS (This Report)
Unclassified
                                                                    21. NO. Of PAGES

                                                                       456
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (»-73)
                                         451

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