vxEPA
            United States
            Environmental Protection
            Agency
            Industrial Environmental Research
            Laboratory
            Research Triangle Park NC 27711
EPA-600/9-80-041
December 1980
            Research and Development
Proceedings
Fourth Symposium on
Fugitive Emissions

Measurement and
Control
New Orleans,  LA
May 1980

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                                          EPA-600/9-80-041
                                          December  1980
               PROCEEDINGS
  FOURTH SYMPOSIUM ON FUGITIVE EMISSIONS
         Measurement and Control
       (New Orleans, LA - May 1980)
                 Compiler

           Christine Wibberley
   TRC—Environmental Consultants,  Inc.
         125 Silas Dean Highway
         Wethersfield, CT 06109
         Contract No.  68-02-3115
             Project Officer

             D. Bruce Harris
Industrial Environmental Research Laboratory
      Research Triangle Park,  NC 27711
INDUSTRIAL ENVIRONMENTAL RESARCH LABORATORY
    OFFICE OF RESEARCH AND DEVELOPMENT
   U.S. ENVIRONMENTAL PROTECTION AGENCY
     RESEARCH TRIANGLE PARK, NC 27711

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                                FOREWORD
The technical  papers  included  in this volume were prepared  for  presentation
at the "Fourth Symposium  on  Fugitive Emissions:  Measurement  and Control,"
held in New Orleans,  Louisiana on May 28-30, 1980.

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 the  General Chairman of the Symposium.

Christine Wibberley of TRC-Environmental  Consultants,  Inc.  was the Symposium
Coordinator and Compiler of  these Proceedings.


                          EPA REVIEW NOTICE

       This document has been reviewed by the U.S.  Environmental
       Protection Agency, and approved for publication. Approval
       does not signify that  the contents  necessarily reflect the views
       and policies of the Agency, nor does mention of trade names
       or commercial products constitute endorsement  or  recommen-
       dation for use.
                                    ii

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                             TABLE OF CONTENTS
                    (Speakers ' names appear in italics)
                                                                     Page
OVERVIEW OF FUGITIVE EMISSIONS 	    1
    Thompson G.  Pace, EPA/MDAD-RTP

FUGITIVE EMISSIONS CONTROL AFTER ALABAMA POWER 	   18
    David I. Brandwein, TRC-Environmental Consultants, Inc.

PARTICLE PRODUCTION FROM SURFACE MINING - PART 1:  VERTICAL
MEASUREMENTS 	   37
    James A. Armstrong and Philip A. Russell, Denver Research
    Institute and Dennis C. Drehmel, EPA/IERL-RTP

PARTICLE PRODUCTION FROM SURFACE MINING - PART 2:  SURFACE
PARTICULATE AND METEOROLOGICAL MEASUREMENTS  	   64
    David L. Dietrich and William E. Marlatt, Colorado State
    University and Douglas G. Fox, Rocky Mountain Forest and
    Range Experiment Station

FUGITIVE EMISSIONS CONCERNS FOR COAL STORAGE AND HANDLING AT
UTILITY GENERATING STATIONS  	   81
    Peter W. Kalika and Pietro Catizone, TRC-Environmental
    Consultants, Inc.

DESIGN, PERFORMANCE TESTING. AND FIELD OPERATION OF AN ISOKINETIC
ELECTROSTATIC PARTICLE SAMPLER 	  101
    Bengt Steen, Swedish Water and Air Pollution Research Institute

ASSESSING HAZARDOUS WASTE TREATMENT FACILITY FUGITIVE ATMOSPHERIC
EMISSIONS	119
    Tim S. Sekulia and B. T. Delaney, Fred C. Hart Associates, Inc.

RESULTS OF FUGITIVE EMISSION MEASUREMENTS AT REFINERIES AND CURRENT
ACTIVITIES IN PETROCHEMICAL UNITS   	  136
    Donald D. Rosebrook, Radian Corporation

EVALUATION OF FUGITIVE EMISSIONS AT A LARGE WOOD-PRODUCTS PLANT  . .  155
    Peter D. Spawn, GCA Corporation

A METHOD FOR MEASURING FUGITIVE EMISSIONS FROM CAST HOUSE
OPERATIONS	168
    James H. Geiger, Betz-Converse-Murdoch, Inc.

STEEL MILL PARTICULATE CHARACTERIZATION AND SOURCE/RECEPTOR
ANALYSES	179
    Philip A. Russell, Denver Research Institute
                                    ill

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                        TABLE  OF CONTENTS (Continued)
 DEVELOPMENT OF  HORIZONTAL  ELUTRIATORS  FOR SAMPLING INHALABLE
 PARTICULATE FUGITIVE  EMISSIONS  ...................  208
    Kenneth M.  Gushing,  Southern  Research Institute

 TECHNIQUES FOR  EVALUATING  SURFACE AND  GROUND  WATER EFFECTS  OF
 DRY ASH DISPOSAL  ..........................  243
    James F. Villaume,  Pennsylvania  Power and Light Company and
    Dennis F. Unites, TRC-Environmental  Consultants,  Inc.

 MEASUREMENT OF  FUGITIVE EMISSIONS FROM INCO'S COPPER CLIFF  SMELTER
 REVERBERATORY FURNACES  .......................  279
    Alan D. Church, W.  J.  Middleton, and P. Gatha, Inco  Metals
    Company

 CONTROL OF FUGITIVE EMISSIONS FROM COAL  STORAGE  PILES  .......  300
    Aivo E. Veel  and  C.  H. Carr,  The Steel Company of Canada, Ltd.

 USE OF ROOF MOUNTED TYPE ESP'S  IN IRON AND STEEL  INDUSTRIES
 IN JAPAN ..............................  306
    Seniohi Masuda, University  of Tokyo

 FUGITIVE HYDROCARBON  EMISSIONS  FROM AN IN-SITU OIL SHALE RETORT   .  .  322
    Gerald M.  Rinaldi and  David R. Tierney, Monsanto  Research
    Corporation

 A WIND TUNNEL STUDY OF  FUGITIVE DUST FROM TACONITE STORAGE  PILES  .  .  334
    Robert B.  Jaako and George  M. Palmer, Purdue University

 COMPUTING DESIGN  CHARACTERISTICS  FOR COAL PILE RUNOFF TREATMENT   .  .  357
    Pamela B.  Katz and John A.  Ripp, TRC-Environmental Consultants,
    Inc.

 EMISSIONS AND EFFLUENTS FROM RAIL AND TRUCK TANKCAR CLEANING ....  375
    Thomas R.  BlaakDood* Monsanto Company

A NEW CONCEPT FOR THE CONTROL OF URBAN INHALABLE PARTICULATES BY THE
USE OF ELECTROSTATICALLY CHARGED  FOG ................  388
    John S.  Kinsey and Carol  E.  Lyons, AeroVironment, Inc., Stuart
    A. Hoenig,  University of Arizona, and Dennis Drehmel , EPA/IERL -
    RTP

CONTROL METHODS FOR FUGITIVE AREA SOURCES  ............. 402
    Dennis  J. Martin,  TRC-Environmental Consultants,  Inc. and
    Dennis  C.  Drehmel, EPA/IERL  - RTP
                                     Iv

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                       TABLE OF CONTENTS (Continued)


                                                                   Page

CIVIL ENGINEERING FABRICS APPLIED TO FUGITIVE DUST CONTROL
PROBLEMS	416
    Dennis C.  Drehmel3 EPA/IERL - RTP and Barry Levene, EPA,
    Region VIII

SPRAY CHARGING AND TRAPPING SCRUBBER FOR FUGITIVE PARTICLE
EMISSION CONTROL 	 426
    Seymour Calvert, Shui-Chow Yung, Richard-Parker, and Julie
    Curran, Air Pollution Technology, Inc., Dennis C. Drehmel,
    EPA/IERL - RTP

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                        OVERVIEW OF FUGITIVE EMISSIONS
                               Thompson G. Pace
                     Monitoring and Data Analysis Division
                 Office of Air Quality Planning and Standards
                     U.S. Environmental Protection Agency
                 Research Triangle Park, North Carolina  27711

                                  May 1980

                                 INTRODUCTION

     Fugitive emissions comprise a major portion of the total national emis-
sions for both Particulate Matter (PM) and Volatile Organic Compounds (VOC).
There are 395 counties or parts of counties in nonattainment with the TSP
National Ambient Air Quality Standard (NAAQS) and 538 in nonattainment of the
ozone standard for which VOC is a major precursor.  The EPA is currently
reviewing the particulate matter standard; one possible outcome may be the
regulation of particles smaller than 15 ym aerodynamic diameter, referred to
as Inhalable Particulate (IP).

     Several regulatory programs are concerned with fugitive emissions.  State
Implementation Plans require the control of PM and VOC to effect compliance
with the NAAQS for Total Suspended Particulate and ozone.  Regulatory programs,
such as the Prevention of Significant Deterioration and regulatory policies
such as the rural fugitive dust policy and the bubble policy are cognizant of
fugitive emissions.  The New Source Performance Standards are beginning to
regulate fugitive emissions and many pollutants regulated under the National
Emissions Standards for Hazardous Air Pollutants have fugitive emissions.
Each of these will be discussed.

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                           NATIONAL EMISSIONS ESTIMATES

      Tables 1  and 2 give national  emissions estimates for 1978 for participate
 matter and Volatile Organic Compound (VOC)  emissions.  The total  emissions
 are taken from background information for the National Air Pollutant Emissions
 Estimates - 1970-78.l   Area source fugitive dust emissions from unpaved  roads,
 entrainment of dust from paved roads, and unpaved airstrips based on 1977
 National  Emissions Data System (NEDS) data  are also included.

      The  distinction between stack and fugitive emissions is based on a
 combination of published reports  and engineering judgment.2,3   Thus,  the
 emissions should  be considered as  estimates only.  The general  criteria for
 defining  stack or fugitive is as  follows:

           Stack emissions include
           - Process and fuel  combustion sources vented directly through a
             stack.

           - Processes  vented  through cyclones or bag  filters considered to be
             an integral  part  of the process.

           - Processes  vented  through stacks serving exhaust or  ventilation
             system normally associated with a process for safety  and  health
             purposes.

           - Process vents with defined airflow sufficient to resemble stack
             exhaust.
           - Exhaust emissions  from mobile combustion  sources.

           Fugitive  emissions  include
           - Open  sources  with  no stack or associated  ventilation  system.
           - Storage vessels.

           - Material handling  and  transfer  losses not normally  collected by
             cyclones or bag filters  as  an integral  part of  the  process.
           -  Leaks  in process equipment.

           -  Evaporative emissions  not  collected and vented  through an exhaust
             hood and ventilation system.

           -  Dust entrainment by motor  vehicles.

           -  Evaporative emissions  from motor vehicle  fuel tanks/crankcases.

          - Wind erosion of open storage piles.

     Fugitives are shown in Table  1 to account for 90 percent of total
particulate emissions.   Major categories include resuspended dust from highway
vehicles, burning of trash and agricultural  land, forest and structural fires,
and industrial  processes.  Industrial fugitives account for 70 percent of all
industrial emissions with the major sources  being iron and steel, primary
copper, cement, crushed stone, brick manufacturing, coal strip mining, and
grain elevators.

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     Table 2 gives a national estimate of VOC emissions.  Total VOC emissions
are about 40 percent from fugitives, with the major source categories being
transportation, burning, solvent use, and industrial  processes from petro-
chemicals, crude and gasoline storage and transfer, degreasing, dry cleaning
and surface coating.

     Controls of fugitive sources are usually tailored to the specific situation.
Typical control techniques include containment and control, surface treatment,
improved seals and equipment design, modified operating practices and in some
cases changing the process itself.  Table 3 summarizes typical control tech-
niques for various fugitive sources.  Several novel techniques being explored
are road carpet as an underlayment for unpaved roads and a charged droplet
fog spray for treating either confined or unconfined plumes.

                  AIR QUALITY IMPACT OF MAJOR FUGITIVE SOURCES

     Volatile organic compounds affect the amount of ozone in the air.  These
VOC provide a means of converting ambient nitric oxide (NO) to nitrogen dioxide
(N02) which does not consume ambient ozone (03).  Subsequently, the resulting
N02 reacts with sunlight to form 03.  The net result of these chemical reactions
is a buildup in ambient levels of ozone.  The resulting high concentrations of
ozone tend to occur on an urban or regional scale.

     Many studies which interpret particulate air quality and emissions data
to estimate source contributions can give some indication of the source con-
tributions as stack versus fugitive.  An example of this would be studies using
optical microscopic analysis of hi-volume sampler filters.  Table 4 summarizes
the results of the analysis of 300 filters from 14 U.S. cities.1*  Using the
component categories defined by the microscopist, it is possible to make a
rough estimate of the fugitive source contributions to ambient air.  First,
assume that mineral matter comes mostly from windblown and mechanically
induced fugitive dust sources and that rubber and paper come primarily from
vehicle resuspension of tire particles and litter.  Also, assume that fugitive
windblown dust from coal storage piles,, iron and steel fugitive sources and
starch from grain handling contributes in part to particulate ascribed to
these categories.  It can then be seen that fugitive dust and emissions con-
tribute perhaps from 50-90+% of ambient! TSP concentrations.

     Fugitive particulate emissions differ from most stack emissions in three
respects:  11 most of the emissions are larger particles and tend to settle
out relatively nerr the source; 21 the emissions are usually emitted at or
near ground level; and 3) emissions generally are at or near ambient tempera-
ture and undergo little thermal plume rise.  These differences result in a
large gradient in ambient concentrations decreasing with distance from the
source.  This has been demonstrated both with modeling studies and with ambient
monitoring studies.5,6  The following is a brief discussion of the ambient
impact of selected sources.

     Unpaved Roads.  The Lincoln-Lancaster County (Nebraska) Health Department
and the EPA performed a study of short term ambient concentrations around an
unpaved road in Lincoln, Nebraska.7,8  For a one hour period, the traffic on
a road in a rural area southwest of Lincoln was increased to over 100 vehicles
per hour.  Hi-volume samplers and dichotomous samplers were located at distances
of 10, 30 and 50 meters from the roadside.

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           Typical concentrations were very high because short term measurements
 were taken under peak traffic conditions.  Hi-vol readings were several  thousand
 yg/m3, and typical  dichotomous sampler readings were in the low hundreds
 (yg/m3) range.  The concentrations at the 30 and 50 meter distances are  plotted
 in Figure 1  as a fraction of the 10 meter hi-vol concentration.  It can  be seen
 that the hi-vol  concentration is reduced substantially at 30 and 50 meters,
 but little decrease is seen in the dichotomous data which measures only  those
 particles smaller than 15 ym.  This suggests that many of the larger particles
 are settling to the ground very close to the source.

      Paved Road Sources.   Data have been collected at many locations which
 suggest a high partlculate matter concentration around paved roads.  Studies
 in Boston,9  Kansas  City10 and Hamilton, Ontario11 all  show these high concen-
 trations which decrease rapidly within 75 meters of the road.  An empirical
 study of data at 79 sites found a relationship between average daily traffic
 (ADT), height of the monitor (HGT) and distance from the road (DIS):


                concentration *    ln
                                 / HG'F + DI52

 Typically,  a  paved  road  might contribute an  average of 15-25 yg/m3  at sites
 located  only  4 meters  from a typical  heavily travelled paved road.5  Current
 EPA monitor siting  guidance suggests  that monitors be located outside of  this
 zone of  direct influence.   Typically,  a monitor might be placed at  least
 25  meters away from a  road and the contribution of that road would  probably
 be  less  than  5 yg/m3 at  that point.   This contribution can be much  higher if
 the road were particularly dusty or dirty.

      Industrial  Sources.   Many industrial  sources  have been sampled by upwind-
 downwind ambient techniques to estimate the  emission factors for processes.
 One recent  study was conducted by the  National  Crushed Stone Association  to
 estimate emissions  from  construction  aggregate  crushing operations.   Table 5
 summarizes  the results of  instantaneous ambient measurements of particles
 smaller  than  10 ym  at  a  distance of 30 feet  downwind of uncontrolled crushing
 operations.   The table shows that significant dust levels  are found just  down-
 wind of  these operations.   One would  not expect fencellne  concentrations  to  be
 this great.12  However,  one would expect much higher concentrations  if particles
 larger than 10 ym were included  1n  the study.

                               EMISSION  MEASUREMENTS

      Two new  measurement methods  are being considered  for  proposal along with
 the  New Source Performance Standards (NSPS) for the  Synthetic Organic  Chemical
Manufacturing  Industries (SOCMI)  and Metallic Minerals  Industries.

      Method 21 applies to  the  determination of volatile organic compound  leaks
from  organic  process equipment.   Specifications and  performance criteria  for
a portable instrument will  be  specified under this method.  Method 22  is
concerned with documenting the presence and duration of visible plumes from
various partlculate fugitive emission sources.  It will specify such parameter*
and how the  emissions are  to be observed and recorded.13

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     Several of the more established methods for measuring fugitive particulate
emissions are being documented in a sampling protocol.11*  These methods include
roof monitor, quasi stack, upwind downwind and exposure profiling.  These
methods are being employed in a major research effort to determine emission
factors for particulate matter.  The program, being coordinated by the EPA's
Industrial Environmental Research Laboratory, is a major program measuring
particulate emissions by particle size from the major stack fugitive source
categories.  New instruments being used in this program include a size selective
inlet for the high volume sampler for use in upwind/downwind sampling and a
horizontal elutriator which will be used in conjunction with the roof monitor
method.  A new sampling train for IP has been developed which uses cyclones to
provide data for 15 pro particles.

                              REGULATORY PROGRAMS

     New Source Performance Standards (NSPS) and National Emissions Standards
for Hazardous Air Pollutants (NESHAPS) are beginning to address fugitive organic
and particulate sources.  Fugitive emissions are of concern in both TSP and
ozone State Implementation Plans (SIP's).  Also, programs such as the bubble
policy and PSD are affected by fugitive emissions.

     NSPS for Particulate Matter — Basic industrial process fugitive emission
sources have been addressed in prior NSPS.  These include such operations as
material transfer, crushing, grinding, process equipment leaks, etc.  Examples
of this include the NSPS for lime plants, asphalt concrete plants, copper,
lead and zinc smelters, coke ovens and grain elevators.  Only recently, however,
have the emissions from windblown and vehicle entrained particulate sources
been mentioned in connection with NSPS.  The upcoming NSPS for the metallic
minerals industries and gypsum plants may include provisions for storage piles,
tailing piles, and haul road emissions within and near the plant boundary.

          A new concept is being considered in developing a NSPS for metallic
minerals.   This is the proposal of Method 22 for visible emissions, as
mentioned earlier.  This method will provide for documenting the duration of
a visible plume from specific process points or operations.  NSPS regulations
in the future may specify the percentage of time that specific processes must
be void of visible emissions.13

     NSPS for Volatile Organic Compounds CVOC) — New Source Performance
Standards for VOC are beginning to consider fugitive emissions.  Two main
categories of sources, petroleum refining and Synthetic Organic Chemical
Manufacturing Plants (SOCMI) are being considered for control of leakage from
pumps, valves, flanges, compressors and cooling towers.  Regulation may require
specific hardware such as double mechanical seals for pumps, or intermittent
monitoring with portable hydrocarbon monitoring devices for such sources as
valves and flanges.  This could be a significant consideration since the SOCMI
produces 350 to 400 basic chemicals at facilities which contain almost 50,000
pumps, 800,000 values and 1.8 million flanges.  Other types of sources such as
storage tanks for volatile organic liquids may follow the recently promulgated
Petroleum Storage Tank NSPS and require floating roofs.15,16

          A third major category of VOC fugitive emissions is the coatings
industry.  Eight new NSPS are being developed now with seven of these scheduled
for proposal this year.  Regulation will probably be based on the emissions

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 allowable  per volume of solids applied.  Controls may be through increasing the
 solids/solvent ratio, collection by solvent recovery systems, such as carbon
 adsorption, or by incineration.17

      NESHAPS — Section 112 of the Clean Air Act, as amended in 1977, requires
 the establishment of emission standards for hazardous air pollutants.  Six
 pollutants have already been listed and NESHAPS have been, or are currently
 being established.  These pollutants are:  mercury, beryllium, asbestos, vinyl
 chloride,  benzene, and radionuclides.  Nine other compounds or elements are
 currently  being considered for listing as hazardous pollutants; these are
 listed in  Table 6.  Of these, arsenic, polycyclic organic matter, perchloroety-
 lene, tricholoethylene, acrylonitrile, and cadmium seem to have a higher prob-
 ability of being listed.18

           Fugitive emissions may be a concern with all of these compounds.
 Certainly, arsenic sources have been identified as major contributors of fugi-
 tive  emissions and ROM's are associated with coking operations.  Acrylonitrile
 storage tanks are a source of fugitive emissions.19  Cadmium has not yet been
 assessed by the EPA for fugitive emissions.

      TSP SIP — Generally, States in nonattainment areas are expected to
 regulate industrial process fugitive paniculate emissions.  However, the policy
 for urban  fugitive dust emissions is less clear.  The EPA and the States/locals
 are planning a series of demonstration studies to evaluate the effectiveness of
 controls on a small scale.  Some of these studies are listed in Table 7.
 Originally, it was thought that many other areas would be proposing demonstra-
 tion  studies at this time.  However, many of these are delayed pending a more
 complete understanding of the ambient contribution of urban fugitive dust
 sources in various particle size ranges of interest.20

      Ozone SIP — The 1979 ozone SIP's generally called for the States to
 adopt regulations for a certain group of hydrocarbon sources (Group I).  These
 Included the coil, can and paper coating Industries, degreasing and gasoline
 marketing.  These regulations must be equivalent in stringency to the levels
 specified  in the control techniques documents for these sources.  The States
 must  also commit to adopt regulations for a second set (Group II) of sources.
 Such  sources Include petroleum refinery fugitive emissions, miscellaneous
metals coatings, flatwood paneling, graphic arts, synthesized pharmaceutical
 products, tire manufacture, perchoroethylene dry cleaners,  gasoline tanker
 trucks, vegetable oil manufacture, and petroleum liquid storage in external
 floating roof tanks.20,21  All of these sources have a significant part of
 their emissions from fugitive sources.

     Bubble Policy — The EPA adopted a new "bubble" concept to consider the
control of certain 1n-plant fugitive sources 1n Heu of placing additional
control on certain stack emissions within a given facility.  Where a source
wishes to trade open source dust controls for the more significant sources of
process emissions* the bubble policy allows sources to demonstrate the equiva-
lency of such trades by Installing the open source controls and then monitoring
the results.22

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     Prevention of Significant Deterioration — In the past, fugitive emissions,
as well as point or stack emissions, were used In determining if a source were
large enough to be covered by PSD regulations.  As a result of a recent court
suit brought by Alabama Power and Light, (AP&L) and other plaintiffs, the EPA
is undertaking special rulemaking to define the manner in which fugitive emis-
sions from certain source categories are considered.  Fugitive emissions will
still be used in calculating the increment consumed by a source, since this
was not affected by the AP&L case.  However, until the rulemaking is complete,
potential emissions are being calculated from stack emissions only for purposes
of determing if a source is subject to PSD.22

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                                   REFERENCES

 1.  National Air Pollutant Emission Estimates, 1970-78, EPA-450/4-80-002, U.S.
     Environmental Protection Agency, Research Triangle Park, North Carolina,
     in preparation.

 2.  Assessment of Fugitive Particulate Emissions Factors for Industrial
     Processes, EPA-450/3-78-107, U.S. Environmental Protection Agency,
     Research Triangle Park, North Carolina, September 1978.

 3.  Compilation of Air Pollutant Emission Factors, AP-42, U.S. Environmental
     Protection Agency, Research Triangle Park, North Carolina, August 1977.

 4.  F. A. Record, National Assessment of the Urban Particulate Problem.
     Volume I, National Assessment, EPA-450/3-76-024, U.S. Environmental
     Protection Agency, Research Triangle Park, North Carolina, June 1976.

 5.  T. G. Pace, An Empirical Approach for Relating TSP Annual  Concentrations
     to Particulate We™ inventory Emissions Data and Monitor Siting
     Characteristics, EPA-450/4-79-012, U.S. Environmental Protection Agency,
     Research Triangle Park, North Carolina, June 1979, page 14.

 6.  Personal communication between T. G. Pace and E. Burt, Monitoring and
     Data Analysis Division, U.S. Environmental Protection Agency,  Research
     Triangle Park, North Carolina, February 1980.

 7.  D. W. Safriet and T. G. Pace, "Preliminary Analysis of Sampling Around
     Unpaved Roads in Lincoln, Nebraska," U. S. Environmental Protection
     Agency, Research Triangle Park, North Carolina, October 1978,  unpublished,

 8.  Personal communication between T. G. Pace and Gary Walsh,  Lincoln-
     Lancaster County Health Department, Lincoln, Nebraska, October 1978.

 9.  R. M. Bradway and F. A. Record, "Program to Measure, Analyze and Evaluate
     Suspended Particulates in Massachusetts," GCA Technology Division, Bedford,
     Massachusetts, Monthly Progress Reports, prepared for Massachusetts
     Technology Development Corporation, Wakefield, Massachusetts,  1978.

10.  Lead Analysis for Kansas City and Cincinnati, Final report from PEDCo
     Environmental to U.S. Environmental Protection Agency, Research Triangle
     Park, North Carolina, under Contract No. 68-02-2515, Task  Order No. 5,
     June 1977, pages 22-23.

11.  Personal communication between T. G. Pace and David Kane,  United
     Technology and Science, Toronto Ontario, Canada, January 1980.

12.  An Investigation of Particulate Emissions from Construction Aggregate
     Crushing Operations and Related New Source Performance Standards,
     National Crushed Stone Association, National Industrial  Sand Association,
     Associated General Contractors of America, National Sand and Gravel
     Association,  Washington, D.C., December 1979.


                                       8

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13.  Personal communication between T.  G.  Pace and Gilbert Wood,  Emission
     Standards and Engineering Division,  U.S.  Environmental  Protection Agency,
     Research Triangle Park, North Carolina, April 9,  1980.

14.  Protocol for the Measurement of Inhalable Participate Fugitive  Emissions
     from Stationary Industrial Sources,  TRC Environmental  Consultants,
     Wethersfield, Connecticut, draft being prepared for U.S.  Environmental
     Protection Agency under Contract No.  68-02-3115,  Task No.  114,  March  1980.

15,  D. G. Erikson and V. Kalcevic, "Emissions Control  Options  for the
     Synthetic Organic Chemicals Manufacturing Industry," draft report
     prepared for the Emission Standards  and Engineering Division, U.S.
     Environmental Protection Agency, Research Triangle Park,  North  Carolina,
     February 1979, page 2-14.

16.  Personal communication between T.  G.  Pace and Susan Wyatt, Emission
     Standards and Engineering Division,  U.S.  Environmental  Protection Agency,
     Reseach Triangle Park, North Carolina, April  11,  1980.

17.  Personal communication between T.  G.  Pace and William Tippett,  Emission
     Standards and Engineering Division,  U.S.  Environmental  Protection Agency,
     Research Triangle Park, North Carolina, April 11,  1980.

18.  Personal communication between T.  G.  Pace and John Fink,  Standards and
     Air Strategies Division, U.S. Environmental  Protection Agency,  Research
     Triangle Park, North Carolina, April  9, 1980.

19.  "Source Assessment:  Acrylonitrile Manufacture,"  Monsanta Research
     Corporation, Dayton, Ohio, NTIS No.  PB-271-969, September 1977, page  7.

20.  Personal communication between T.  G.  Pace and Brock Nicholson,  Control
     Programs Development Division, U.S.  Environmental  Protection Agency,
     Research Triangle Park, North Carolina, April 14,  1980.

21.  Stephen V. Capone and Malcolm Petrorcia,  Summary of Group II Control
     Techniques Guideline Documents for Control of Volatile Organic  Emissions
     from Existing Stationary Sources.  EPA-450/2-80-001, December 1979.

22.  Personal communication between T.  G.  Pace and Kirt Cox, Control Programs
     Development Division, U.S. Environmental  Protection Agency,  Research
     Triangle Park, North Carolina, April  14,  1980.

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 TABLE 1.   Estimate of Particulate Matter Emissions (103 tons/yr)
 Source Category

 Transportation
   Highway Vehicles
     LDV
     LOT
     HDG
     MC
     HDD
   Railroads
   Aircraft
   Vessels
   Misc.  off-highway-gasoline
   Misc.  off-highway-diesel

 Stationary Fuel  Combustion

 Industrial  Processes
   Iron and steel
   Primary aluminum
   Primary copper
   Primary lead
   Primary zinc
   Ferroalloys
   Gray iron foundries
   Secondary non-ferrous  meteJls
   Chemicals
   Cement
   Sand and gravel
   Crushed stone
   Phosphate rock
   Brick  and clays
   Lime
   Glass
   Asphalt batching
   Concrete  batching
   Coal  cleaning
   Coal  strip mining
   Gypsum
   Asphalt Roofing
   Pulp mills
   PIywood
   Cotton  ginning
   Grain  elevators
   Food and  grain mills
   Cattle  feed  lots
   Petroleum refining

Solid  Waste
   Incinerators
  Open burning

Miscellaneous
  Forest  Fires
  Agricultural  Burning
  Structural fires
  Unpaved road vehicle travel
Stack Emissions

     884
     537
     308
      57
      75
       4
      93
      69
      82
      28
      16
     152

    4150

    2097
     225
      67
      35
       4
       1
      39
      30
      68
     189
      80
       0
       0
      16
     185
     116
      29
     127
      18
      15
       0
      66
       8
     263
      26
      13
     395
       1
       0
     81

     219
     219
       0

       0
      0
       0
       0
       0
                         TOTAL    7350
Fugitive Emissions

     395 (5354)
     395 (4950)1
     257
      48
      25
       0
      65
       0
      <9)2
       0
       0
       0
    4666
     6903
      39
     3223
      373
      203
      19
     123
      12
      19
     78i
      47
    1478
      30
     296
      48
      0
      36
      92
      0
     195
      1
      0
      0
      0
      0
     349
      7
      25
      0

    256
      0
     256

     735 (38,735)
     574
      92
      69
(38,000)"

   6052 (49,011)
1 NEDS area source total shown in parentheses represents entrainment of
  dust from paved roads.  Tranportation fugitive total also includes tire wear.

2 NFDS area source total for unpaved airstrips.

3 Includes ore mining emissions all  assumed to be fugitive.

u NEDS area source total for unpaved roads.  Other totals shown in parentheses
  include this total.
                                    10

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                       TABLE  2.   Lstimate  of  National  VOC  Emissions  (10'  tons/yr)


                       Source Category                     Stack  Emissions           Fugitive  Frissions
Transportation
Hiqhwdy Vehicles'
LDV
LDT
HOG
HC
HDD
Railroads
Aircraft
Vessels
Misc. off-hiqhwdy-gasoline1,2
Misc. off-hiqhway-diesel3
Stationary fuel combustion
Industrial Processes
Petroleum refining
Petrochemicals1 ]
8459
7035
4257
1038
1356
174
210
188
227
476
361
172
326
8640
617
758
                                                                                        3266
                                                                                        3167
                                                                                        2327
                                                                                         577
                                                                                         227
                                                                                          36
                                                                                           0
                                                                                           0
                                                                                           0
                                                                                           0
                                                                                          99
                                                                                           0
                                                                                        6322
                                                                                         343"

                         Crude oil  and natural  gas
                           production                             0                      2566
                         Crude oil  and gasoline
                           storage  tanks7                          0                      627
                         Gasoline bulk terminals/plants8           0                      615
                         Gasoline service  stations9                0                     1082
                         Gasoline/crude oil  transfer1^             o                      572
                         Plastics                               374                        0
                         Other Chemicals11                       583                        0
                         Adhesives                               254                       28
                         Coke                                      0                       49
                         Fermentation                             0                       90
                         Vegetable  oil                           21                        0
                         Bakeries                                46                        0
                         GTass                                    2                       64
                         Dry cleaning                           100                      258
                         Degreasing                               0                      571
                         Graphic  arts12                         348                       39
                         Surface  coating13                      2304                      256
                         Misc. organic solvent11*               3060                      340
                         Otner processes1"                       173                       19

                       Solid Waste  Disposal                      380                      480
                         Incineration                           380                        0
                        ^pen  burning                             0                      480

                       Miscellaneous                              0                     2815
                         Forest fires                             0                      642
                         Agricultural burning                     0                       85
                         Structural fires                          0                       47
                         Architectural coating                    0                      331
                         Cutback  asphalt paving                   0                      686
                         Miscellaneous solvent use                0                     1024

                                                TOTAL        17,805                   12,883
 1  Based on classification of  exhaust  emissions  as  stack emissions and evaporatlve/crankcase emissions as  fugitive emissions

 2  Includes farm,  construction.  Industrial  engines,  snowmobiles, lawn and garden  tractors, and off-highway motorcycles.

 3  Includes farm,  construction,  industrial  engines.

 **  Includes emissions  from process  drains,  cooling  towers, asphalt blowing, valves and  seal leaks, sampling, etc.

 5  Assume estimated  emissions  from  storage  and handling losses, and other fugitive sources as fugitive emissions.

 6  Assumed all  fugitive  stack  emissions  from fuel combustion  equipment Included under stationary fuel combustion.

 7  Includes tanks  at oil  fields  and refineries only.

 8  Storage tanks only.

 9  Stage I and  Stage II.

10  Includes ship and barge transfer and  filling, rail  and  truck tankers.

11  Petrochemicals  include all  products 1n SIC 2865,  2869.  Other chemicals  Include other  organic and  inorganic  chemicals.

12  Assumes that solvent vapors are  collected by  an  exhaust system  and  vented  through a  stack.   It  is  assumed  that  lot of
   emissions are fugitive, escaping the  exhaust  system or  carried  out with  products  and evaporated later (allowance).

13  Assumes emissions occur from  spray  booths and baking ovens vented to  stacks.   Evaporative emissions from flash-off of
   solvent are  assumed to be ICO! of total emissions  (allowance).

i*  Assumed to be predominantly stack emissions,  allowance  IDS of total emissions  reported as fugitive.
                                                            11

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                                TABLE  3

            TYPICAL CONTROL TECHNIQUES FOR VARIOUS FUGITIVE SOURCES
OPEN SOURCES

STORAGE VESSELS

MATERIAL HANDLING AND TRANSFER

LEAKS IN PROCESS EQUIPMENT


PROCESS EVAPORATIVES


VEHICLE DUST ENTRAINMENT


VEHICLE EVAPORATIVES

WIND EROSION
VARIOUS (FOGGERS. WATERING. OPERATING PRACTICE)

FLOATING ROOFS/SEALS, VAPOR COLLECTION/RECOVERY

CONTAINMENT, WATER SPRAYS, FOGGERS

IMPROVED SEALS/EQUIPMENT DESIGN, ROUTINE INSPECTIONS
IMPROVED MAINTENANCE/OPERATING PRACTICES

VAPOR COLLECTION/RECOVERY, SOLVENT SUBSTITUTION,
SOLIDS - SOLVENT RATIO

PAVED - STREET CLEANING, DEPOSITION CONTROLS
UNPAVED - PAVING, CHEMICAL STABILIZATION, ROAD CARPET

PCV, CONTAINMENT

PILE CONTOURING, WIND BREAKS, CONTAINMENT,
WATERING, CHEMICAL STABILIZATION

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          TABLE 4



U.S. COMPOSITE SUMMARY OF FILTER ANALYSES

COMPONENTS
MINERALS
* QUARTZ
* CALCITE
* FELDSPARS
* HEMATITE
* MICA
OTHER
COMBUSTION PRODUCTS
SOOT:
OIL
* COAL
MISC. SOOT
GLASSY FLY ASH
INCINERATORY FLY ASH
OTHER
BIOLOGICAL MATERIAL
POLLEN
SPORES
* PAPER
* STARCH
MISC. PLANT TISSUE
LEAFTRICHOMER
MISCELLANEOUS
* IRON OR STEEL
* RUBBER
OTHER
QUANTITY, percent
AVERAGE
(65)
29
21
5
10
1
1
(25)

7
5
5
6
2
1
( 3)
1
1
1
1
1
1
( 7)
1
7
1
RANGE
3-99
1-84
1-93
0-35
0-65
0-15
0-46
1-89

0-86
0-52
0-88
0-30
045
0-19
0-90
0-45
0-2
0-3
0-10
0-8
0-18
0-50
0-25
0-50
0-15
                    13

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                      TABLE 5
             MEAN DUST CONCENTRATIONS FOR PARTICLES
           SMALLER THAN 10 jum MEASURED 30 FEET DOWNWIND
PLANT
A
B
C
D
E
F
G
STONE TYPE
GRANITE
SAND & GRAVEL
SAND & GRAVEL
TRAPROCK
LIMESTONE
LIMESTONE
LIMESTONE
PRIMARY
CRUSHER
200 ± 853
130 ± 170
170± 140
640 ± 590



SECONDARY
CRUSHER
350 ± 210
440 ± 390
570 ± 200
930 ± 640
68 ± 43b
170±640
2200± 1000
TERTIARY
CRUSHER
11401740


210 ± 290


810 i 450
FINES
CRUSHER
1600 1 290


410 1 280



a(STANDARD DEVIATION)

&WET PROCESS

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TABLE 6.  Compounds Currently Being Considered for Listing as
          Hazardous Pollutants
                    Arsenic
                    Polycyclic Organic Matter
                    Perch!orethylene
                    Tri chloroethy1ene
                    Acrylonitrile
                    Cadmium
                    Methyl Chloroform
                    Methylene Chloride
                    Toluene
     a Compounds listed first have a higher probability of being listed.
                                       15

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                     TABLE 7
  DEMONSTRATION STUDIES PLANNED BY STATES AND THE EPA
     TO EVAULATE CONTROLS FOR FUGITIVE DUST SOURCES
       STUDY
         CONTROLS EVALUATED
PORTLAND, OREGON
DENVER, COLORADO
MINNEAPOLIS, MINNESOTA
LAS VEGAS, NEVADA
TUCSON, ARIZONA
VACUUM SWEEPING OF PAVED STREETS IN
INDUSTRIAL AREA

REDUCE FUGITIVE DUST DUE TO SANDING
FOR SNOW CONTROL

CONSTRUCTION GENERATED DUST- ESPECIALLY
MUD CARRYOUT

PAVING OF GRAVEL ROADS AND MODIFY
SUBDIVISION CONSTRUCTION  PRACTICES

CONTROL OF TAILINGS PILES AND
UNPAVED ROADS

-------
                    FIGURE 1
 RELATIVE SHORT TERM CONCENTRATIONS MEASURED

BY DICHOTOMOUS SAMPLERS AND HI-VOLS AT DISTANCES

 OF 10, 30 AND 50 METERS FROM AN UNPAVED ROAD
       1.0
     £

     Z 0.8

     E

     o
     T—

     O
       0.6
     >

     H
     HI

     cc 0.4



     O
       0.2
     o
     z
     o
     o
.SAMPLER
I
s
I I I
                10             30


                  DISTANCE FROM ROAD, meters
             50
                           17

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                FUGITIVE EMISSIONS CONTROL AFTER ALABAMA POWER
                              DAVID I. BRANDWEIN
                        ASSOCIATE ENVIRONMENTAL COUNSEL

                         TRC ENVIRONMENTAL CONSULTANTS
                           WETHERSFIELD,  CONNECTICUT

                                   MAY,  1980

                                   ABSTRACT
     Recent   studies   indicate   that   traditional   stack-oriented   control
strategies 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
emission  sources  will also  be required  in  order   to comply  with  EPA's
regulations  on  Prevention  of  Significant Deterioration (PSD).    This  paper
attempts  to  summarize  the federal  regulations  and  policies applicable  to
fugitive  particulate  matter  sources  under   the  Clean  Air  Act.   Pertinent
provisions of  EPA's  regulations and  guidelines  for nonattairunent and  PSD
areas are discussed.   Particular emphasis is given to  discussing  the  impact
of  the   recent  Alabama Power decision  and  EPA's proposed  regulations  of
September 5,  1979 dealing  with PSD and nonattainment new source review.
                                      18

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                                 INTRODUCTION
     On June  18,  1979,  the United  States Court of Appeals for  the  District
of Columbia issued  its  initial ruling in  the  case of Alabama Power  Company
v.  Costle.1   This  decision made  substantial  changes  to EPA's  regulations
for  preventing  significant deterioration (PSD) of  clean air.   Due to  the
close  relationship  between  the  PSD  program  and  EPA's  regulations  for
nonattainment areas,  the Alabama  Power  decision  will affect  both  sets  of
regulations.

     The  issues  addressed  in  Alabama Power cover  the .full spectrum of  the
PSD  regulations promulgated by EPA  in mid-1978. The decision  directly  dealt
with  how  fugitive  emissions  may be  regulated under  the  Clean  Air  Act  and
with  EPA's fugitive dust exemption.   Perhaps  more importantly,  through  its
broad  discussion  of what  sources  and modifications  are  subject  to  review,
which pollutants must be considered,  and  how geographic  location affects  the
type of review, the Court  indirectly  made fugitive emissions  the subject  for
increased regulation in the future.
      OVERVIEW OF  DEVELOPMENTS SINCE THE CLEAR AIR ACT AMENDMENTS OF  1977

     The  1977 Amendments  to  the Clean  Air  Act  were   the  foundation  for
today's PSD  and  nonattainment  new source  review  program.   The  1977 Amend-
ments gave rise  to EPA's 1978 PSD regulation  which, in  turn,  directly lead
to  the  court  challenge resulting  in Alabama  Power.   Alabama Power,  both
directly  and indirectly,  will  force  major  substantive  changes   in  EPA's
regulation of fugitive  emissions and  to  EPA's  PSD  and  nonattainment  new
source  review program.  Thus,  it is  useful to  understand  these  post-1977
developments.
                                 Nonattainment

     The  widespread failure  of  many  of  the  nation's  air  quality  control
regions  (AQCR's) to attain  the  National  Ambient  Air Act Standards (NAAQS) by
the original  July  1,  1975  deadline created a  dilemma concerning  the  legal
approvability of new  sources  which would add to levels of pollution already
in violation of the law.

     EPA  responded  to  this  problem with promulgation  of  its national Offset
Policy  on December 21,  1976.2   The  essence of  the Offset  Policy  was that
major  new growth  should  be  allowed  in  nonattainment  areas  only  if  air
quality  is  improved as  a result of  the growth.  This  improvement  comes by
way of  contemporaneous emission  reductions from  existing sources so  as to
more  than "offset" the  emissions  which  will  be  added by  the  proposed new
source.

                                     19

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      The  Offset Policy  imposed  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 in compliance or on  a  schedule of compliance with  the
 State  Implementation  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  (SIP)  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
 were  to have  submitted  plan revisions to EPA which conform  to  new Part  0 of
 the Act.   These revised plans are  designed  to replace EPA's  Offset Policy
 and were  to have been approved  by  no later than June 30,  1979.   Failure to
 adopt and receive EPA approval of the revised plan by this deadline triggers
 a statutory ban on  major new sources (of the nonattaining  pollutant)  in the
 nonattainment area.    Many  states have incorporated elements of  the Offset
 Policy  into their SIP.

      Table  I  summarizes the development  of  the  nonattainment provisions and
 the Offset Policy.
                    Prevention of  Significant  Deterioration

     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 unimportant phrase
in the original law 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 did not prevent
significant deterioration of clean air.

     This challenge was  ultimately  successful, and on December  5,  1974, EPA
promulgated regulations  to  prevent  emissions  of sulfur dioxide  and particu-
late  matter from  significantly  deteriorating  air  quality  in  areas  where
concentrations of  those  pollutants were lower than the applicable national
ambient  standards.3    EPA   incorporated   its  PSD  regulations  into  the
implementation plan of each state pursuant  to Section 110(c) of  the Act and
established a procedure  by which EPA  could delegate its  PSD responsibility
to states.

                                     10

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                          TABLE  I

                 CHRONOLOGICAL DEVELOPMENT
                   OP EPA'S OFFSET POLICY
           AND THE ACT'S NONATTAINMENT PROVISIONS

      Original  Deadline  for  Attaining  the Primary NAAQS
                           7/1/75

             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

                   Revised SIPs Due to EPA
                           1/1/79

    EPA Promulgates Major Revisions to Its Offset Ruling
                          1/16/79

         Initial Ruling in Alabama Power vs. Costle
                          6/18/79

        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

    EPA Proposes Revisions to  PSD and  Nonattainment  Rules
                           9/5/79

EPA Publishes Final Revisions to PSD and Nonattainment Rules
                            6/80

        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
                             21

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     The  regulations  prohibited construction of stationary sources in any of
19  specified  categories  unless  EPA  (or  a  delegated state)  had  issued  a
permit  evidencing  that  the  source  would  apply  "best  available  control
technology"  (BACT)  for  sulfur  dioxide  and  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  that system,
clean air areas could  be classified  as Class  I,  II, or  III.   In  Class  I
areas,  small increases of  sulfur  dioxide and  particulate matter would  be
significant.   In  Class II  areas,  moderate  increases  were allowed,  and  in
Class III  areas,  increases  were permissible  up  to an ambient standard.   The
regulations  initially classified all PSD areas as  Class II, but gave states,
Indian  governing  bodies,  and  federal land  managers  the  opportunity  to
reclassify their lands under specified procedures.

     The  1977  Amendments  affirmed  EPA's development of  the  PSD concept.3a
The  new statutory  scheme follows  the outline  of the pre-existing  regula-
tions,4   but is  generally more  comprehensive and restrictive.  Some  of  the
more significant changes introduced by the 1977 Amendments include:

       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  indeter-
          minate status)  must  be formually listed by  EPA.   EPA
          issued   this   list   on   March  3,   1978.5    Several
          revisions have been made since March 3, 1978.6

       o  More Restrictive  "Increments" -  The  new law  reduces
          the  allowable  short-term   increments   for   SC-2  and
          particulates  in Class  II and  III  areas.   Class  I
          increments remain  the same.7

       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
          Amendments were enacted   (8/7/77)  are now  designated
          as mandatory Class  I  areas.   These  areas  may  not  be
          redesignated.8

      o  More  and  Different  Sources  Subject to  PSD  Review -
          The new Act  increases the number  of source categories
          subject  to PSD  preconstruction review from 19  to  28.
          New  and  modified  sources  within  one  of  these  28
          categories  are  subject   to   PSD  if   they   have  the
          potential  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  pollutant.9   Major  sources  of   fugitive
          dust  were  covered by  the 250  ton  criteria.
                                     22

-------
       o  More  Restrictive  Definition  of  BACT  -  Under  the
          original  PSD  regulations,  Best   Available   Control
          Technology (BACT)  could  not be more  restrictive than
          the New Source  Performance Standards   (NSPS)  appli-
          cable  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,  technology,   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   SO 2   and
          particulate  matter as under the prior  regulations.1°

       o  Substantially  Increased   Monitoring   and   Modeling
          Requirements -  Under  the  original PSD  Regulations,
          applicants   merely  had   to   demonstrate,   through
          atmospheric   diffusion  modeling,  that  the  proposed
          emissions would   not  violate   the  allowable  incre-
          ments.  The  new  law  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  -  EPA's original PSD regulations  applied only
          to  SO2  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,  photo-
          chemical  oxidants,  and nitrogen  oxides)  by  no later
          than  August  7,  1979.    These   regulations  will  take
          effect  one year  after  promulgation and must utimately
          be  incorporated  into all State  implementation plans.
          PSD  regulations   for  lead  must  be   promulgated  in
          1980.12

     On November  3, 1977, EPA  took  four  regulatory actions toward implement-
ing  the  Act's  new  PSD  requirements.13   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 proposal  of  regulations  giving guidance  to the
preparation of  SIP  revisions called  for  by the  new  PSD review 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 preconstruc-
tion review  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.


                                     23

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      EPA  formally  promulgated  its  new  PSD  regulations and  SIP  revision
 guidelines on June  19,  1978, three  and one-half  months after  its  original
 self-imposed deadline  of  March  1,  1978.I4   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  pollution  permits  prior  to March  1,  1978  had  to  commence
 construction on or before  March  19,  1979 in order to  be  exempt  from the  new
 requirements.   This was the  deadline for the  submission of  revised  SIPs  to
 EPA.

      Immediately upon promulgation,  the  1978 PSD regulations  were  challenged
 by  a  number of  industry  and  environmental  groups,  as  well  as state  regula-
 tory  agencies.   These  individual  lawsuits  were consolidated  into a  single
 action  before the U.S.  Court of Appeals for the  District of Columbia.   On
 June  18,  1979,  the court  issued  its  initial ruling  in Alabama Power  Company
 v.  Costie.

      The  Alabama Power  opinion  was  issued  by   the court "per curium"  which
 means that the specific  opinions of  individual  judges  of the court were  not
 included.   While  the opinion  reflected the  court's  final  rulings  on  the
 questions presented by the petitions for review,  more detailed opinions  of
 the court were  promised  in  the  late summer or early fall  of 1979.   EPA's
 response  to  the  court's  remand order was expected  to follow  the issuance  of
 these detailed  opinions.   However,  when it  became  apparent  that  the  Court
 would not issue  its  supplemental  ruling  until  late in  the year, EPA  decided
 to  go ahead  and  propose its new regulations.

      On  September 5,  1979, EPA  proposed comprehensive  changes to  its PSD
 regulations  in  conformance with  the Alabama  Power  summary  opinion.15  At
 the  same  time,  the Agency proposed  an  overhaul  of its  nonattainment new
 source  review guidelines  to  make  them consistent  with  the proposed PSD
 provisions.

      The  D.C.  Circuit Court  of  Appeals  issued its  supplemental  opinion  in
Alabama  Power on December  14,  1979.16  With   two exceptions,    the  final
opinion  made  no  major   changes  to   the  summary  opinion. ^   EPA   is  now
 finali2ing its regulations for implementing the final  Alabama Power  ruling.
These regulations are expected to be promulgated in June 1980.

      Table II summarizes the development  of the PSD program.
                   NEW SOURCE REVIEW AND FUGITIVE EMISSIONS

     New  source  review  is  the  regulatory  program  under  which major  new
sources and  major modifications  to  existing sources undergo  a  preconstruc-
tion  review  process,  either  under   PSD  (generally  implemented  by  an  EPA
Regional Office)  or  under  nonattainment (generally  implemented by  a  State
through its SIP).
                                     24

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                          TABLE II
                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
                           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
                          6/19/78

      Major Sources with Allowable Emissions  in Excess
      of 50 Tons Per Year May 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

       Initial Ruling in Alabama Power Co. vs. Costle
                          6/18/79

Deadline For EPA Approval or Disapproval of the Revised SIPs
                          7/19/79

   EPA  Proposes Revisions to  PSD  and Nonattainment  Rules
                           9/5/79

            EPA Publishes Final Revisions to  PSD
                  and Nonattainment Rules
                            6/80
                             25

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      There are two aspects to new source review:

      1)    an applicability  determination to decide  what source
           or modification is  subject to review, what pollutants
           must  be  reviewed/  and whether  PSD  or  nonattainment
           (or in some cases, both)  rules apply; and

      2)    a substantive  review,  after the applicable  rules are
           identified,   to   determine   what   technology-based
           standards  apply   (BACT,   LAER),   what  air   quality
           analyses must be performed/ and so on.

      Alabama Power  focused  on   the  applicability issues  and  so will  this
 paper.   The substantive issues can  be briefly summarized as follows:

      For PSD;

           1)   The   application   of   Best   Available   Control
               Technology (BACT);

           2)   Ambient air quality  analyses  (modeling,  monitor-
               ing,  and  other impact analyses);  and

           3)   Consumption of the  PSD increments.

      For Nonattainment;

           1)   The  application of   Lowest  Achievable   Emission
               Rate  (LAER);

           2)   Certification   of   statewide  compliance   for   all
              major  sources  by the  owner;

           3)  Obtaining  of offsets  (emissions  reductions)   from
               existing  sources   in  the  area  of   the   proposed
               source; and

           4)  A  net  air quality  benefit and reasonable  progress
              toward  attainment of  the NAAQS.

     It  is  important  to  note that PSD rules apply in any area where at least
one  NAAQS  is  attained.18   Because  almost  every  area   in   the  U.S.  is
attainment  for at  least  one criteria  pollutant,  the  PSD  review will  be
required  for  major  new   and  modified  sources,  regardless  of  where  they
locate,  if the source is  "major"  for the attainment pollutant.  Accordingly,
most discussions of new source review, including this paper,  focus on PSD.

     The  remainder of this paper  will focus on  four  specific issues  and how
each was addressed  in a)  EPA's  1978 PSD regulations, b) Alabama  Power, and
c) EPA's proposed PSD and nonattainment rules of September 5, 1979:

     1)    What  sources   or  modifications  are   subject  to  new
          source review?


                                      26

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     2)    What pollutants are to be included in the review?

     3)    How does  the  source's  location  in a  "PSD area"  (an
          attainment  or  unclassified  area)   or  nonattainment
          area affect the review? and

     4)    What is the status of the fugitive dust exemption?

     Before  beginning  the  discussion  of  these  issues,   it   is  useful  to
clarify what is meant by "fugitive emissions" and "fugitive  dust".

     The Clean Air Act does not  provide defintions of  these terms.   Fugitive
emissions are  generally understood to refer  to emissions  from  a  stationary
source that emanate from other  than  a stack or  chimney.  As discussed  later
EPA has proposed  to define  the  term  "fugitive  emissions" as  those  emissions
which do  not pass through  an  opening which the owner  or operator  uses  for
ventilation,  such  as  a stack,   chimney,  roof   vent  or  roof  monitor.19
Fugitive  emissions  may  be  particulate  matter,  volatile  organic  compounds
(VOC's)  or any other pollutant.

     On the other hand,  fugitive  dust is  uncontaminated soil  particles  which
become  airborne  as  a  result  of  human  activities.20   The  most  common
sources  are  haul  roads,  exposed soil  surfaces,  and  soil  storage  piles.
Fugitive dust is particulate matter only.
                             Source Applicability

     Section  165 of  the  Act  imposes  the  new  PSD  preconstruction  review
requirements  on  "major  emitting  facilities"  seeking  to  locate  in any  PSD
area.  The term  major emitting  facility  is  then defined as any source in one
of 28 categories having a potential to emit  100  tons per  year or  more  of any
pollutant  regulated  under the Act.   The  term also embraces  any  source  in a
category  other  than one of  the  28  listed  categories with  a  potential
emissions' increase of 250 tons per year or more of any regulated pollutant.

     The  term "potential  emissions"  (or "potential to  emit")  is  not defined
in the Act and was one of the issues under Alabama Power.

     Under  EPA's   pre-Alabama   Power  regulations   (hereafter,   the   "old"
regulations),  EPA  defined "potential to  emit" for purposes  of  both PSD and
nonattainment  new   source   review,   as  a   source's   maximum  uncontrolled
emissions.    Sources  with   "potential"   emissions  in  excess  of  the  PSD
thresholds  (100  or  250  tons, depending  on  the  source  category)  were  deemed
to  be  "major stationary  sources,"  and,  therefore,  were  subject to  PSD.
Sources  could escape most of  the PSD requirements on a pollutant-by-pollu-
tant  basis, however,  if  that pollutant's "allowable"  emissions  could  be cut
to below  50 tons per year.   The basic goal  of this approach was to encourage
sources  to reduce  emissions below  the  50 tpy level in  order to qualify for
an expedited  and less expensive review.

     EPA  included  fugitive   emissions  in  calculating  a plant's  potential
emissions  as  a  matter  of policy.   Surface mines  were  considered  as major
sources  even  if  their potential emissions were solely fugitive.


                                      27 -

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      The  court  in  Alabama  Power  reversed  EPA  and  held  that  a  source's
 potential  to  emit  must  reflect  emissions  after controls  are  incorporated.
 Major new  stationary  sources must  be  defined on the  basis of  their  actual
 allowable emissions.

      On the inclusion  of  fugitive emissions towards a  source's  potential to
 emit, the Court was quite  specific.   The court held that,  although  EPA does
 have  the  authority  to  regulate  fugitive  emissions  and  fugitive   dust,
 generally,  and  mining  operations   specifically,   EPA  must   address  the
 inclusion  of   fugitive  emissions  through  rulemaking,  as  required   under
 Section 302(j)  of the  Act.  The  court,  therefore,  remanded the  PSD regula-
 tions as  they  applied  to fugitives,  and directed  EPA  to accomplish  its
 original objectives  through formal rulemaking.

      To the surface mining industry's arguement  that a  surface mine  is  not  a
 source because a  mine  is  not within  the scope  of  the definition of  source
 ("a building,   structure, facility,  or  installation"),  the Court  stated that
 EPA had  the  discretion  to define  the  term   "facility"  by the  concept of
 "common  sense  industrial groupings" so  as to  encompass a  source  of  fugitive
 emissions such as a major  mining  operation.   Again, however, EPA would have
 to do so through  rulemaking.

      In  response  to the  court's decision EPA  proposed  to amend  the defini-
 tion of  "potential to  emit"  in  the existing  regulations.   As proposed,  the
 new definition would provide that  the  term means "the capability at maximum
 capacity  to   emit   a   pollutant  after   the  application   of air  pollution
 control  equipment."   However,  the agency has  incorporated  an  irrebuttable
 presumption  into  the  definition  that   a source  will  operate   at  maximum
 capacity around the  clock,  365 days per year.

      In  response   to  the court's  holdings, EPA  also proposed  that  certain
 industrial  fugitive  emissions, to the  extent reasonably quantifiable, may be
 included in determining whether  a source or modification  is "major".   This
 proposal affects  the definition of the  term   "potential  to emit"  and this
 applies  to both PSD  and nonattainment new  source  review.

     First, EPA proposed to define  "fugitive  emissions"  as  those emissions
 which  do not pass through  an  opening which the owner or  operator  uses for
 ventilation, such as a  stack,  chimney,  roof  vent or  roof monitor.21   (EPA
 would  also  delete  the  existing  definition   of fugitive   dust  at  40 CFR
 51.24(b)(6) and 52.21(b)(6)  (1978).)

     Second, EPA  proposed  to  incorporate into the  existing  regulations the
principle that  rulemaking must precede  the inclusion of "fugitive emissions"
 in an applicability determination.2^

     Finally,   the  Agency  proposed  to   list   the   stationary  sources  in
Table III whose fugitive  emissions are  to be  taken  into  account.  Fugitive
emissions will  also  be  counted  if they are  from any other stationary source
category  which,  at  the time  of the applicability  determination, is  being
regulated under section 111 or 112 the Act.

     EPA  will  be  considering  during  1980  the  need  for   additional  source
types to be added  to the list,  including surface mines.

                                     28

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                                  TABLE III
 1)   Coal Cleaning Plants
 2)   Kraft Pulp Mills
 3)   Portland Cement Plants
 4)   Primary Zinc Smelters
 5)   Iron and Steel Mill Plants
 6)   Primary Aluminum Ore Reduction Plants
 7)   Primary Copper Smelters
 8)   Municipal Incinerators
 9)   Hydrofluoric, Sulfuric, or Nitric Acid Plants
10)   Petroleum Refineries
11)   Lime Plants
12)   Phosphate Rock Processing Plants
13)   Coke Oven Batteries
14)   Sulfur Recovery Plants
15)   Carbon Black Plants
16)   Primary Lead Smelters
17)   Fuel Conversion Plants
18)   Sintering Plants
19)   Secondary Metal Production Plants
20)   Chemical Process Plants
21)   Fossil Fuel-Fired Boilers
22)   Petroleum Storage and Transfer Units
23)   Taconite Ore Processing Plants
24)   Glass Fiber Processing Plants
25)   Charcoal Production Plants
26)   Fossil Fuel-Fired Steam Electric Plants
                                      29

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      Before  leaving  the discussion  of  source  applicability  and  fugitive
 emissions  it  is  important  to  note  three  activities  dealing  with  coal
 conversion that  are exempted  from  new source  review.   These types  of  coal
 conversion are  not subject  to new  source review  because,  either  by statute
 or  by  regulation,  they  are not  considered  "modifications":  Conversion  to
 coal (or other alternative fuel):

      1)   Pursuant  to an  order  under  the  Energy  Supply  and
           Environmental Coordination  Act  of  1974 (ESECA)  or any
           superceding legislation  (such as  the  Power  Plant and
           Industrial Fuel Use Act of 1978);23

      2)   If, prior to January 6,  1975, the source  was capable
           of accommodating such fuel24. or

      3)   Pursuant to an order or rule  under section 125  of the
           Act  ("Measures  to  Prevent  Economic  Disruption  or
           Unemployment").

      These provisions  were  not  under  review   in  Alabama  Power and  remain
 unchanged.
                            Pollutant Applicability

      Once one knows  whether  a major  source  or major  modification is  being
 proposed, one must determine  which pollutants must  be  reviewed.

      Under the "old" regulations, a source was subject to new source review
 only  for those pollutants for which it was "major"  (i.e., emitted  in amounts
 greater  than  or  equal to 100/250 tons  per year).  If a modification was less
 than  100/250  tons per year for any pollutant,  the modification was not major
 and there was no new source review.

      Alabama  Power sent EPA  back to the drawing board  on its definition of
 modification,  holding that  EPA's  interpretation  was  inconsistent  with the
 language  of  the  Act.   Specifically, the  court ruled  that  any  (non-exempt)
 modification  of  a stationary source is  subject to  the  Act's PSD provisions
 if  there  is  any significant net  increase in  emissions.  Thus,  the 100/250
 ton threshold was  rejected.

     The  court did hold  that  an insignificant,  or  "de minimus", net increase
 in emissions  may be exempted  by EPA.  EPA has proposed a  list of de minimus
 levels for each pollutant regulated under the Act.    (See Table IV.)

     This  change  will  have  far  greater effect  for  PSD  review  than  for
 nonattainment  review because after  Alabama  Power  many more  pollutants  have
 been swept into  new  source review.   Where previously review  was required for
only  "major pollutants",  now  review is triggered for  all  pollutants emitted
 in greater than de minimus amounts once one pollutant becomes major.

     A BACT review must be performed  for each pollutant  emitted  in  greater
than de minimus  amounts.   However,  some  pollutants may be exempted  from the


                                     30

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                                  TABLE IV

                      EPA'S PROPOSED DE MINIMIS LEVELS
                 FOR DETERMINING "SIGNIFICANT  NET  INCREASE"*

                Carbon monoxide—100 tons Per year.

                Nitrogen dioxide—10 tons per year.

                Total  Suspended  particulates—10  tons  per
                year.

                Sulfur dioxide—10 tons per year.

                Ozone—10  tons  per year of  volatile organic
                compounds.

                Lead—1 ton per year.

                Mercury—0.2  tons per year.

                Beryllium—0.004 tons per year.

                Asbestos—1 ton per year.

                Fluorides—0.02 ton per year.

                Sulfuric acid mist—1 ton per year.

                Vinyl chloride—1 ton per year

                Total Reduced Sulfur:

                    Hydrogen sulfide—1 ton per year.
                    Methyl  mercaptan—1 ton per year.
                    Dimethyl sulfide—1 ton per year.
                    Dimethyl disulfide—1 ton  per  year.

                Reduced Sulfur  Compounds:

                    Hydrogen sulfide  (see above).
                    Carbon  disulfide—10 tons  per  year.
                    Carbonyl sulfide—10 tons  per  year.

* Note - EPA has added  a  second set of ambient impact "de minimis"  levels  to
  limit  the air  quality   review  requirements  only  for  certain  pollutants
  which the source would have the  potential  to emit, in significant  amounts
  but which have an insignificant  ambient  impact.
                                     31

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 air quality analysis  part of new source  review  if,  as  a  result of screening
 modeling, the pollutant is below a second de minimis level  which is based on
 air quality impacts.

      For nonattainment review, pollutant  applicability is  far  narrower.   To
 trigger  new  source review,  a source  or modification  must be  major for  a
 pollutant  for which  the  area  is  nonattainment.    And  once  nonattainment
 review is triggered, other pollutants are not swept in as under  PSD rules.

      An  example  will illustrate  this change.   Under  the  "Old" rules,  the
 addition of a coal pile with  fugitive emissions of  15 tons per year  would
 not  result  in  new  source  review  because  the  modification was  not  maior
 (  100/250 tons per  year).   After  Alabama Power  and  under EPA's proposed  de
 minimus levels, the addition of the coal pile  is  a major  modification (being
 greater  than  the  10  tpy de  minimus  level for  particulates) , and  a BACT
 review for the coal pile would be  required.   However, detailed air  quality
 analyses may  be  avoided  if  the facility can demonstrate  that  the  impact  is
 less than 5  ug/m3 (24  hour average).


                           Geographic  Applicability

      The next  stop  in the new source  review  applicability determination  is
 deciding which set  of regulations  apply  for  the pollutants subject  to  the
 review - PSD,  nonattainment  of  both.

      Under  the 1977 Clean Air  Act Amendments, all areas  of the nation have
 been designated  as subject  either  to PSD  or  nonattainment   requirements.
 With  respect  to  new  source   review,  however,  the   "old"   EPA regulations
 focused  on the area impacted by  the source, irrespective  of the attainment
 status  of  the   area  in  which  the  source  sought   to  physically   locate.
 Specifically,  EPA's  PSD  regulations  extended  the  permit  requirements  of
 section  165  to  all  sources,  wherever  located,   if  the emissions  from  the
 source had a signification impact on any clean  air area.

     The  court held in Alabama  Power  that the Act's PSD requirements are not
 triggered  by  sources located in nonattainment  areas simply because they have
 an  adverse impact on a clean air  area within the same State.  Only where the
 source is located  in  a  nonattainment area of  a  neighboring state  will  its
 impact on  adjacent  clean  areas  trigger  the  PSD  review.   The  court's
 reasoning  is   based  upon  a number  of  provisions  in   the  Act which  seek  to
prevent  interstate PSD conflicts.   With  respect  to   intrastate  air quality
management  planning,  however,  the  court  noted  a  "federalist policy"  of
deferring  to  the  States on   matters  relating   to   their  internal  growth
management.  The  final court  ruling  indicates that  PSD  permits  cannot  be
required  for  sources in nonattainment  areas  even if  interstate  impacts are
 involved.  SIP's,  however, must address such impacts.

     Although  EPA  has  petitioned  the DC Circuit for  reconsideration on this
aspect of the  decision, it  appears  doubtful  that the  agency  will succeed  in
changing  the  court's mind.  In its  September   5,  1979 proposed  regulations,
EPA has,  therefore,  developed  a change in prior policy  designed to overcome
a potential  gap  in  the  New Source  Review program which  could  materialize.


                                      32

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Specificallyf  under  the  "old"  regulations,  proposed  major   sources  in
designated nonattainment  areas  with no significant impact on  the violations
can  be  exempted  from  nonattainment  requirements  because  they  are  made
subject  to  PSD  preconstruction review.   But,  under  Alabama  Power and  the
regulations  now  being  proposed, such  major  sources would  be  able  to  avoid
both PSD and nonattainment NSR requirements.

     EPA has determined that such a result  is contrary to the  intent  of the
Clean Air Act  and has, therefore,  proposed  to extend  the  nonattainment NSR
requirements of  both the  Offset Policy and Section 173 of  the Act  to  cover
major  sources  everywhere  in   the   designated  nonattainment  area.25   This
rule would apply  regardless  of  whether the source could  demonstrate  that it
would not significantly impact the specific point(s)  of violation.
                          The  Fugitive  Dust  Exemption

     Following the 1977 Amendments  to  the Clean Air  Act,  EPA created through
rulemaking a partial exemption  from new  source  review requirements for major
emitting   facilities   of   fugitive  dust.   The   regulation  maintains  the
requirement  that  such  sources  apply  best  available  control  technology
(BACT),  but  exempts them  from  the otherwise-required  showing  that particu-
late  emissions  from   the  facility  will not  exceed  either the  applicable
national   ambient   air    quality    standards   (NAAQS)   or  the   allowable
increments.26

     In  Alabama  Power, the  court  vacated  (i.e., eliminated)  the exemption
and  sent  it  back  to  EPA  for  further  consideration.   As in  the case  of
fugitive  emissions,  the  court  held  that  EPA  had   the  legal  authority  to
accomplish  its stated objective,  but  had  failed to  comply with  the rule-
making requirement imposed by the Act.

     In  remanding the fugitive dust  exemption  for  agency reconsideration,
the  court suggested a regulatory  approach  under which  fugitive  dust could
become a "regulated"  pollutant  (by  controlling it under  Section  111  of the
Act)  but would  not be  a  "criteria"  pollutant  within  the meaning  of  the
national  ambient  standards  or  the PSD increments.   Under  this approach,
major  new  and modified  sources  of  fugitive  dust  would  have  to  control
emissions with BACT, but  would  not have  to model its air quality  impact with
respect   to   the  ambient  particulate  increments   or  standards,  thereby
achieving the  same result as under the exemption.

     However,  EPA has proposed to  eliminate   the  exemption  entirely,  both
from  the  PSD  regulations  and from  a  parallel  provision  in  the  offset
ruling.27   The  agency gave  no  reason  for  its decision   to  eliminate  the
exemption.   It is important  for  surface mining  operators  to note, however,
that  under  the Surface Mine Control and Reclamation  Act  (SMCRA), the Office
of  Surface  Mining (OSM)  within the  Department  of the  Interior  has begun to
regulate  the  fugitive  dust aspects  of mining  in a manner  substantially more
stringent  than EPA.   OSM  regulations  will  require,  among  other things, the
preparation  of  a fugutive  dust  plan  and  the  imposition  of  fugitive dust
control  technology.28
                                      33

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                                   CONCLUSION
      The  Alabama   Power  decision  will  have  a  significant  impact  on  the
 regulation of  fugitive  emissions for  the  forseeable future.  But  interest-
 ingly,  the impact  will  not be due to  the  sections  of the decision  directly
 addressing fugitive emissions and fugitive dust.   The impact will come  from
 the greater number of sources and modifications subject  to new source  review
 and EPA's implementation of the  de minimus  concept.

      The court's  holding  that  EPA  may include  fugitive  emissions  toward
 determining a  source's  "potential  to  emit"  in order  to determine whether
 there is a major  source  or modification only  placed  a temporary road  block
 in  EPA's path.  By the  time  this paper  is published, EPA will have amended
 the definition of  "potential  to emit"  to  include  fugitive  emissions to  the
 extent  reasonably  quantifiable  for  most major source  categories  (although
 surface  mines  have not yet  been  included).

      Of  more  concern is the  whole change in the concept  of "major modifica-
 tion".   Because this term  now means, for  PSD  purposes,  any significant  net
 increase  of any  pollutant once the source is major for any  (including a
 different)  pollutant,  there will  potentially be many more  "major modifica-
 tions"  and many   more  new  source   reviews  required.    (For  nonattainment
 purposes,  the  "significant  net increase"  must still be for the pollutant  for
 which the  source is major).

      This  increase in PSD new source reviews will be substantial unless  the
 bubble  policy  can  be   easily  used  by  a   source  to  achieve,  through  an
 increasingly complex "numbers game", no  net  increase  in a source's emission
 rate.  As  fugitive emissions  become  more quantificable,  sources will have to
 obtain  offsets  for  such  activities  as  material  storage   piles  and  haul
 roads.  Depending  on the final de minimus  level for particulate  matter,  the
 addition  of coal  piles  alone  could  trigger  new source review.   Any facility
contemplating  conversion  to  coal  should,   however,  carefully  review   the
available exemptions from new  source  review for certain conversions.

     Once  new  source review  is  begun/  either  partially  or  entirely due to
sources of  fugitive emissions,  the   substantive aspects  of  the  review come
into  play.  What   is BACT  or  LAER for  sources  of  fugitive  emissions  - for
coal  piles,  for  haul   roads,  for   surface mines?   What  is  involved  in
performing  the  air quality  analysis  -  the  modeling  and the monitoring  - of
these emissions?    These  two  questions,  together  with  how to  "reasonably
quantify"  these emissions,  will  be  the fugitive  emissions  issues  of  the
 '80's.
                                      34

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                                  FOOTNOTES
 1.   13 ERC 1225 (C.A.D.C.  1979).

 2.   41 FR 55524.

 3.   39 FR 42510]  40 CFR 52.21.

3a.   For  a  discussion of  the development  of the  PSD  program, see  Raffle,
     Bradley I., "Prevention  of  Significant Deterioration  and  Nonattainment
     Under the Clean Air Act  - A Comprehensive Review"  Environment Reporter,
     Monograph No.  27 (May 4,  1979).

 4.   39 FR 42510 (December 5,  1974).

 5.   43 FR 8962.

 6.   40 CFR 81.

 7.   Clean Air Act (CAA)  Section 162.

 8.   CAA Section 162.

 9.   CAA Sections 165 and  169(1) .   The Amendments defined  a  major source in
     terms  of  its   "potential  to   emit"   but  do  not   define   the  term
     "potential."   EPA's  1978 PSD  regulations define "Potential to emit" as
     the capability  at  maximum  capacity to emit  a pollutant in  the absence
     of air pollution control equipment.  This was at issue in Alabama Power.

10.   CAA Sections 165(a) (4) and 169(3).

11.   CAA Section 165
-------
 18.  CAA  Section 161.

 19.  See  Proposed Sections 51.24(b)(20) and 52.21(b)(20)  (1979).

 20.  40 CPR  51.24(b)(6)  and 52.2Kb) (6) (1978).

 21.  Supra,  n.  19.

 22.  See  44  FR  51930  and  Proposed  Sections  51.24(b)(3)   and   52.21(b)(3)
     (1979).

 23.  40 CPR  52.21{b)(2)(c)  (1978) and  40 CFR  51,  Appendix S, Paragraph II(A)
     (5)  (ii)  (d).

 24.  40 CFR  52.2(b) (2) (d)   (1978)  and  40 CFR  51,  Appendix S, Paragraph II(A)
     (5) (ii)(c).

 25.  See  Proposed Sections  51.24(1)(2)(i)  and  52.21(1)(8)(i)   (1979).

 26.  40 CFR  51.24(k)(5)  and 52.21(k)(5)  (1978).

 27.  44 FR 3274.

28.'  30  CFR Parts 782-784.   See  especially Sections 783.18 and 784.26.
                                      36

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                    PARTICLE  PRODUCTION FROM SURFACE MINING:

                         PART 1--VERTICAL MEASUREMENTS

                  James  A. Armstrong and Philip A. Russell
                          Denver Research  Institute
                              Denver, Colorado
                              Dennis C. Drehmel
                    U.S.  Environmental Protection Agency
                 Industrial  Environmental Research Laboratory
                    Research Triangle Park, North Carolina


                                    ABSTRACT

     An investigation of the vertical  extent and downwind transport of
fugitive dust plumes resulting from various operations at a surface coal
mine was conducted using a tethered balloon sampling system.   This EPA-
sponsored field study took place concurrently with  a Bureau of Land Manage-
ment-sponsored field program conducted  by the USDA's Forest Service and
Colorado State University to assess the overall air quality impact of
strip mine activities on the surrounding environment.

     A balloon was used to carry aloft  three lightweight wind directional
particle samplers.  One sampler was attached directly to the balloon; the
other two were attached to the tetherline at selected distances from the
balloon.  This arrangement allowed for  the simultaneous collection of
dust samples at three heights above the ground at various downwind
distances from the mine operations.  A  fourth sampler was located near
the balloon launch site to monitor ground level concentrations.  Dust
samples were collected on Nuclepore and Millipore filter substrates
which were analyzed by optical and scanning electron microscopy.

     The size distribution, concentration and composition versus height
of the collected dust samples are presented.  Time lapse movies of mining
activities at the test site during tethered balloon sampling are also
discussed.
                                       37

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                                    INTRODUCTION

      For the past 3 years, the Denver Research  Institute  (DRl) has been
 involved in developing and utilizing balloon-borne particle sampling
 systems which possess both vertical and horizontal mobility and are
 capable of sampling at specified altitudes for extended periods of time.
 Two of the systems developed employ remote controlled samplers and have
 been used to monitor emissions from the plumes of coal-fired power
 plants1 and a portland cement plant.2  The third sampling system, which
 is described in this paper, was developed to investigate the vertical
 extent and downwind transport of fugitive particle emissions from point
 and nonpoint sources.  The system was recently employed to monitor dust
 emissions from various operations at a surface coal mine and to evaluate
 the feasibility of using the tethered balloon sampling method to ultimately
 determine emission factors using an exposure profiling technique.

      The DRl field study at the surface coal  mine in Colorado was sponsored
 by the Industrial  Environmental Research Laboratory,  U.S.  Environmental
 Protection Agency, Research Triangle Park, North Carolina.  The study
 took place concurrently with a Bureau of Land Management-sponsored field
 program performed  by the U.S. Forest Service  and Colorado State University
 to assess the overall air quality impact of strip mine activities on  the
 env i ronmen t.

      A preliminary field test at  the mine  was conducted from June 4 to
 June 8,  1979«  to check out and evaluate  sampling  techniques.   A more
 extensive field investigation was conducted at  the mine from July 30
 through  August  8,  1979.   Results  of the  DRl study for  the  latter  test
 period are  presented,  including the evaluation of selected airborne dust
 samples  from a  dragline operation versus dust from hauling,  dragline,
 dressing  and  scraping operations,  as well  as  dust samples  from an active
 haul  road.   The mineral  content of selected soil  and road  bed  samples  is
 also presented.  Documentation  of balloon  sampling  and  mine  site  activities
 using  time  lapse photography  is discussed.

                                    BACKGROUND

      It  is now widely  recognized  that fugitive particle emissions  contribute
 significantly to the measured  levels of total suspended particulates
 (TSP) found  in both urban and rural environments.  These emissions are
 believed  to be responsible for  the  failure of many areas to attain  the
 national primary air quality standards for TSP.  Major open sources of
 fugitive emissions include unpaved  roads, paved roads, surface mines,
 storage piles, construction activities, agricultural tilling, wind
erosion of harvested cropland and forest and  brush fires,  including both
wildfires and prescribed burns.3  Other sources include iron and steel
 foundries, smelters, and refineries.1"5'6  Considerable effort  is being
devoted by numerous researchers in establishing the particle emission
 levels and rates from fugitive sources so that cost effective control
strategies can be developed for such emissions.
                                       38

-------
     Of the fugitive sources listed above,  open sources (except forest
and brush fires)  emit particles primarily in a coarse size range of
greater than approximately 2.5 ym in equivalent aerodynamic diameter.
These particles,  classified as mechanically generated, are believed to
be the most significant sources of fugitive emissions contributing to measured
ambient TSP levels.  Fugitive particle emissions produced by combustion
processes, such as from forest and brush fires and from furnace operations
at foundries and smelters, are typically in a fine particle size range
less than 2.5 3-im.  The chemistry of the coarse versus fine particles
also differs:   coarse particles are usually more basic; and fine particles,
more acidic.7

     The traditional method of monitoring airborne particles from fugitive
sources has been to use ground-based high-volume samplers.  The samplers
are usually at considerable distances both upwind and downwind from the
source being sampled.  Dispersion modeling is normally used to interpolate
the source strength from the HiVol data.  Considerable error can be
incurred when using this technique because of the often limited number
and location of sampling sites and due to the current simplicity of the
atmospheric dispersion models.  Complications are further increased when
the source is not wel1 defined.

     Samplers mounted on towers have been used successfully to characterize
fugitive dust emissions from paved and unpaved roads employing an "exposure
profiling" technique which  is based on the isokinetic profiling concept
used for conventional source testing.8  Particulate emissions are measured
directly downwind of the source being sampled by placing a grid of
samplers in the effective cross-section of the plume.  Emission factors
are subsequently determined by a mass-balance calculation.  The exposure
profiling technique eliminates the need to use dispersion models to
estimate emission  rates from fugitive sources.  A two dimensional vertical
array of samplers must be used when sampling a point or area source with
this technique while line sources   (e.g., haul roads) require a one
dimensional vertical grid of samplers.

     Major limitations of the exposure profiling technique are the
practical height of the sampling towers and their lack of mobility.   Results
of the study presented here indicate that these limitations can be
overcome using balloon systems so that the exposure profiling technique
can be extended to a larger number of fugitive source sampling applications.

                        TETHERED BALLOON SAMPLING SYSTEM

     The sampling system  basically consists of a balloon system, wind
vane samplers and a ground-based sampler.

                                 Balloon System

     A commercially available blimp-shaped balloon having a buoyant gas
capacity of 3.25 m   is used as the airborne platform  for  the three wind
vane samplers discussed below.  Tethered balloons up  to this size do  not
require Federal Aviation Administration waivers to Federal Aviation
Regulations, Part  101, in order to  be operated.  When  inflated with


                                       39

-------
 helium, this balloon has a static lift of 1.9 kg at sea level.  The
 balloon is constructed of polyethylene and, for ease in observation and
 safety, is red.  The balloon is attached via a tetherline to a portable
 winch which contains a battery operated forward/reverse, variable speed
 motor for tetherline control,  a 12-volt sealed lead/acid battery
 pack and charger system have been incorporated into the winch  housing so
 that the winch is totally self-contained.  The winch weighs 27 kg including
 the battery pack modification.  The extremely lightweight tetherline
 has a breaking strength of 535 newtons and a mass to length ratio of 0.4
 kg/km.

      This balloon system is capable of lifting a package weighing 1.2 kg
 to maximum altitudes of 800 to 1,000 m in winds of 6 to 8 m/s.   Flight
 performance of the balloon is still  reasonable in winds of 10 to 12 m/s
 but the maximum altitude attainable is somewhat reduced.   The balloon is
 designed to survive in winds up to 20 m/s.

                                Wind Vane Samplers

      Three wind directional  particle samplers,  each weighing  ^00 g,  were
 employed in this study.   A schematic of this  sampler type  is  shown  in
 Figure  1.   The vertical  tube of the  sampler attaches to the horizontal  tube
 at  a point where the wind vane balances the forward tube  extension  such
 that the extension is always horizontal.  The  tubes and wind  vane are fiber-
 glass.   A 37  mm filter cassette ,is  attached to  the  front  end  of  the
 horizontal  tube.   An assembly housing  the pump,  battery pack  and voltage
 regulator is  attached to the bottom  of the vertical  tube.   The weight of
 these components ensures that the  sampler maintains the orientation
 shown in Figure 1.   The  samplers are attached  to  the balloon  or  tetherline
 by  nylon lines.   Swivels are tied  to the ends of  the nylon  lines  that
 attach  to  the samplers while quick disconnect clamps are  tied  to  the
 ends that  attach  to  the  balloon or tetherline.  The wind vane configuration
 ensures  that  the  samplers  point Into the wind during sampling.   Observations
 have shown  this  to be  the  case  even  in  very light winds  (<1 m/s).

      Two of the wind vane samplers are  equipped with a  diaphragm pump;
 the  third uses a  piston  pump.   All pumps are powered with battery packs
 consisting of  three  lithium cells wired in series which provide 8.1
 volts.   This  voltage  is  regulated down  to 5 volts to ensure constant
 pumping  rates.  Flexible tubing is used to connect  the  pumps to the 37
 mm filters held  in plastic cassettes.  The sampling  probe shown attached
 to the filter cassette in Figure 1 was not used during  this field study:
 all airborne dust samples were  collected on open-faced  filters.  Each
 sampling pump  is activated at the time that the associated sampler is
 launched.  For this study, 0.2 urn Nuclepore filter  substrates were employed;
 the corresponding air sampling  rates of the diaphragm pumps and the piston
 pump were 2.75 i/m and 1.2 l/m, respectively.   Millipore filters having
an effective pore size of 0.8 urn were also used, resulting  Fn air flow
 rates of 5-1 A/m and 3.k H/m for the diaphragm and  piston pump samplers,
 respectively.
                                        40

-------
FILTER
CASSETTE
         LITHIUM
         BATTERIES
                                   SWITCH
                                 VOLTAGE
                                 REGULATOR
     Figure 1.  Wind vane particle sampler.

-------
-ts
1-0
OVERBURDEN
    PILE
                                ACTIVE PIT
                                          r
MAIN GROUND-BASED
SAMPLING NETWORK
                                                   -TOPSOIL
                                                    SCRAPING
                                                    AREA
                                                                    08/l/79

                                                                    °8/5/79
                                                                             B
                                                                                                   NOTES:
                                                                                                   O BALLOON LAUNCH LOCATIONS
                                                                                                     AND DATES

                                                                                                  M.T. METEOROLOGICAL TOWER

                                                                                                   A TIME LAPSE CAMERA LOCATED
                                                                                                    ~3.5 km FROM M.T. ON 7/30/79

                                                                                                   B TIME LAPSE CAMERA LOCATED
                                                                                                    -2.5 km FROM M.T. ON
                                                                                                     7/31 to 8/5/79
                                                                                                       08/2/79
                                                                                                    08/3/79
                                                                                                       100 m
                                                 Figure  2.   Strip mine sampling  site.

-------
                              Ground-Based Sampler

     In addition to the three balloon-borne samplers,  a fourth sampler
equipped with a piston pump was always located near the balloon launch
site to monitor dust concentration at ground level.  This sampler was
not wind directional.   It was positioned at a height just above the
local vegetation with the open-faced filter cassette pointing upward.

                                FIELD OPERATIONS

     A description of the field site, the operation of the balloon sampling
system, the collection of soil samples, and the documentation of sampling/
mining operations are discussed.

                                   Field Site

     The mine site, in arid western Colorado, is on the north face and
near the bottom of a gently sloping mountain range.  Its  elevation is 1,950
m.   In terms of dispersion modeling, the terrain would be classified as
relatively complex.  Dry conditions existed during field sampling.  Morning
temperatures varied between 8°C and 15°C; afternoon temperatures varied
between 31°C and itO°C.  Surface radiational inversions existed most
mornings.  Winds were predominantly from the west.  During the mornings,
the winds were light and sometimes variable; by early afternoon, they
would become strong and often gusty.  The site in Figure 2 shows balloon
launch locations and dates of balloon sampling.  Main elements of the site
consisted of an active coal pit, a coal storage pile, haul roads and a
topsoil scraping area.  A dragline removed overburden from the pit,  coal
was  loaded in the pit and, on most days, the pit coal seam was blasted.
During several of the sampling days, topsoil was removed from an area
east of the pit and coal from the storage pile was loaded onto haul
trucks.  The storage pile and the area adjacent to the pit were dressed
periodically.

                           Balloon Sampling Operations

     Balloon sampling consisted of first locating the balloon system at
a selected distance downwind from the mine operation(s) to be sampled.
The first sampler would then be attached to the balloon an.d the pump of
this sampler would be activated by connecting the battery leads shown in
Figure 1.  The balloon would be launched until a selected length of
tetherline was reeled off the winch.  The winch spool would be stopped,
the second sampler would be attached to the tetherline and its pump
would be activated.  Again the winch spool would be actuated until the
appropriate length of tetherline was reeled out.  The winch would be
stopped, the third sampler would be attached to the line and  its pump
would be activated.  Finally, the winch would be started and additional
tetherline would be run out until the balloon reached the desired uppermost
sampling height.  Appropriate distances were previously marked on the
tetherline to assist  in placing the samplers at the desired vertical
separation distances.  The ground-based sampler would also be activated
at this time.
                                       43

-------
      Flight operations were conducted at downwind distances varying from
 150 to 1,000 m from selected mine operations with sampling heights up to
 J20 m.  Sampling times were typically 4 to 6 hours.

      Three balloon sampling operations, in which the collected dust
 samples have been examined in detail, are discussed below.  A log of
 these operations is presented in Appendix A.

 Dragline Versus Additional Mining Operations

      From 0700 hours to 11 A3 hours MDT on August 1  and again from 0830
 hours to 151& hours on August 5,  balloon sampling was conducted at the
 same launch site shown in Figure 2.   During both sampling periods, the
 wind at an altitude of 75 m was  predominantly from the west.  The surface
 wind velocity measured by a ground based meteorological  station varied
 from 1.8 m/s to 3.1 m/s and from 1.3 m/s to 2.7 m/s during the sampling
 perfods on August 1 and August 5,  respectively.   The launch site was
 approximately ^00 m east of the  dragline operation  at the active coal
 pit.  Mine activities  during the  sampling period on August 1 included
 coal hauling, overburden removal  by  the dragline,  dressing operations
 and  topsoil  scraping,  while only  the dragline was  in operation on August
 5.   Dust samples were  collected at elevations of 0.5 m,  10 m,  20 m and
 75 m.

 Haul ing Operations

      A balloon sampling operation  was  conducted  from 1155  hours  to IkkQ
 hours  on August 6 to investigate  the extent  of  dust  emissions  from an
 active haul  road.   During  this sampling  period,  the  surface  wind  velocity
 was  2.2 m/s  to 3-1  m/s.  The  balloon was  located approximately  150 m
 directly downwind from a curve in  the  haul  road  and  dust  samples  were
 collected at an elevation  of  30 m.

                              Soil  Sample Collection

      Loose soil  samples were collected from  the middle of  the main  east-
west  haul  road,  from the spoils of an overburden drill hole  and  from the
overburden pile  adjacent to the dragline.  These samples were used  to
 identify  the  typical mineral composition of  the mine  site.   The samples
were collected  by hand and were stored in sealed plastic bags for  later
 laboratory analysis.

                   Documentation of  Sampling/Mining Operations

     A  16 mm  zoom lens Bo lex movie camera equipped with an MR I intervalometer
was used  to take  time  lapse movies of all tethered balloon sampling operations,
The movies were  taken  to document the downwind sampling distances, the
activities at the mine site and the genera] atmospheric conditions during
 sampling.  The camera  locations are shown in Figure 2.  The camera framing
 rate was  typically one frame every 3 seconds.
                                     44

-------
                                     RESULTS

     Analyses of airborne particles, bulk soil samples, and time lapse
movies are discussed.

                                Particle Analysis

     Both optical and scanning electron microscopy were utilized to
determine the composition, size distribution and concentration of the
collected particles.  In general, optical microscopy was limited to
larger particles (diameters >_ 5 Um) which permitted rapid determination
of coal and mineral components.  Scanning electron microscopy was employed
to perform detailed size and compositional analyses of particles ranging
from 0.5 ym to  100 ym in diameter.

     All Millipore filters exposed  in the field were examined using
optical microscopy.  In the laboratory, mid-sections of the Millipore
filters were carefully excised and permanently mounted on microscope
slides.  Examination during the mounting procedure assumed that particle
displacement was minimal.  A mixture of k percent flexible collodian in
amyl acetate was used to clear the Millipore filter material and adhere
particles to its surface.  After the collodian/amyl acetate mixture
dried, a cover  slip was added using Permount to make a permanent slide
for future observations.

     Upon returning to the laboratory,  it was observed that some of the
particles collected on the Nuclepore filters had become dislodged from
the filter substrate and had redeposited on the walls of the capped
cassettes.  This was especially noticeable for the fraction of the
larger particles.  Subsequently, the particles on these filters and
filter cassettes were resuspended and transferred to glass vials using
filtered (0.2 ym filter material) ethyl alcohol.  Resuspension was
carried out in  a positive pressure glove box.  Air to the glove box was
filtered through dual absolute filters.  Samples for subsequent optical
and electron microscopy were prepared by refiltering the resuspended
particles through 0.2 ym Millipore media.  Filter mid-sections to be
used for electron microscopy were mounted on SEM stubs using double
sided adhesive  tape.  A gold/palladium alloy was then vacuum sputtered
onto the samples to make them electrically conductive for high resolution
electron beam observations.  The thickness of the gold/palladium coating
was approximately 10 nm.

     The optical analysis was performed using a Zeiss Photomicroscope  II
at magnifications of 36x, I60x and 250x.  Polarized light with the
polarizing elements slightly out of phase was used to permit simultaneous
recording of mineral and coal particle  images.  Highly opaque images
were assumed to be coal.  Inhomogeneous particles containing both coal
and mineral were commonly observed.  For the purpose of the optical
analysis, any particle containing coal was classified as a coal particle.
Particle counting was performed from photomicrographs, examples of which
are shown in Figure 3-

-------
                            August 1, 1979
  August 5, 1979
                        75 Meter Elevation
 75  Meter  Elevation
-
-
                        0.5 Meter  Elevation
0.5 Meter Elevation
                      Figure  3.  Optical micrographs of sampled particles  (mine operations:  August 1

                                hauling, dragline, dressing and scraping; August 5 - dragline only).

-------
     More detailed information was obtained using a Philips  501B scanning
electron microscope equipped with an EDAX 9100/60 energy dispersive x-
ray analyzer.  A number of randomly selected fields of 80x and  640x were
examined for each sample.   The EDAX analyzer was  used to identify the
relative elemental composition of the particles.   An example of the x--
ray analysis of three types of particles collected during this  field
program is illustrated in Figure k.  The gold peak recorded  in  the
sample spectrum is produced by the gold/palladium alloy coating.  It is
notable that the coal particle contains significant amounts  of  elements
normally associated with minerals  (Al,  Si, K, Ca, Fe) whereas the carbon
black particle, probably diesel,  produces no observable x-ray spectra.
Carbon black particle aggloremates were only rarely observed in the
samples examined.  In general, particles having a gold peak the same as
or less in magnitude than Si (or other major elemental peaks) were
classified as mineral in this analysis.  As with  the optical microscopy,
particle counting was performed from photomicrographs.  The composition
of the particles was noted directly on the micrographs prior to counting.
Examples of the SEM micrographs are shown in Figure 5.

     Equivalent spherical  diameters of the basically irregular mineral
and coal particles were estimated by averaging the maximum length of
each particle and its maximum width taken at right angles to the length.
All particles observed on a micrograph were classified by size and composition
and tallied into a size class based upon a geometric progression of the
/2.9  For example, 13 size  intervals, ranging from 0.6-1.0 ym to 60.0-
85.0 ym, were employed for mineral and coal particles observed on the
SEM micrographs.  After classifying the mineral and coal particles
separately, the particles counted per interval at 640x were extrapolated
to the number which would be present at a magnification of 80x.  For
intervals which overlapped  the two magnifications, weighted averages of
the number of observed particles were employed.  The total number of
particles in each interval across the entire active filter was then
calculated and, in turn, divided by the total volume of air sampled
through the f i 1 ter.

     The mid-size diameter of each size interval  was used to calculate  a
spherical particle volume.  These volumes were then multiplied by the
appropriate number counts per volume of air sampled and by assumed par-
ticle densities so that cumulative and differential mass distributions
as functions of particle size could be plotted.  The assumed density of    ,
the mineral particles was 2.6 g/cm ; that for the coal particles, 1.4 g/cm .

     Cumulative mass distributions for particles  sampled on August 1,
5 and 6 are presented in Figures 6, 7 and 8, respectively.  The straight
lines through the data points were fitted using a least squares routine
applied in log-normal space.  If a distribution  is log-normal,   it will
occur as a straight  line  when  plotted  on  a  log-probability  graph.   In
general,  the data is  approximately log-normal.   The  mass  median diameters
d   ,  are  the 50  percent values  of  the  distributions  while the  geometric
standard  deviations,  O  ,  are the 84.1  percent  values  divided by the  50 percent
values.   Table  1  summarizes d   ,  a , and  the total  number of mineral and
coal  particles  counted  from the micrographs  for  each sample analyzed.
                                       47

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                     IO.O  K>V
Figure k.  SEM micrograph showing particle  types  sampled at
           the strip mine and associated x-ray  spectra.

-------
-•
c
                         75 Meter Elevation
                                    0.5 Meter Elevation
                           Figure 5.
SEM micrographs of particles sampled on August 1, 1979 (mine

operations:  hauling, dragline, dressing and scraping).

-------
        SflMPLE  5N MINERflL
                          SRMPLE  5N CORL
  99.9

  39.0

590.0
§50.0
  10.0

   1.0

    .1
T
4-
      1
      10
D  (micron*)
           100
      10
0  (microns)
100
                         75 Meter Elevation
        SflMPLE 8N MINERflL
                          SflMPLE  8N COflL
  89.9
                 18
           D (»1oron«>
                                  10
                            0  (micron*)
                         0.5 Meter Elevation
   Figure 6.   Cumulative mass distributions for mineral  and coal particles
             sampled at two elevations on August 1, 1979.
                               50

-------
       SRMPLE  17N MZNERflL
                          SflMPLE 17N COflL
 99.9

 99.8 • -
                 18
            D 
-------
        SRMPLE 41M MINERRL
  99.9

  99.0


?90.0



J 90.0
O

£ 10.0 j-


   i.0|-

    .1
                   r
                   4-
       1           10

            0 (mforona)
100
       99.a

       99.0
                                   590.0
                                    $80.0

                                    O
        1.0


         .1
               SRMPLE  41M CORL
      4-
      10

0  (micron*)
                      Cumulative Mass Distributions
        SRMPLE  4iM  MZNERRL
Q
01
O
    10
                  10
            0  Cnlorona)
     Q
     9
     O
         10
               SRMPLE 41M CORL
                                                     T
                       10

                 0  (mtoron*)
                     Differential Mass Distributions
          Figure 8.  Cumulative and differential mass distributions

                   of mineral and coal  particles sampled at an

                   elevation of 30 meters on August 6, 1979.
                                52

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                                   Table 1.  Sampling Results

Date
8/1 /79a



8/5/79b

8/6/79°
Filter
Number
5N
6N
7N
8N
17N
20N
41M
Sampl ing
Elevation
(m)
75
20
10
0.5
75
0.5
30
Total Parti
Counted
Mineral
438
414
327
262
523
382
138
cles
Coal
221
165
234
137
283
130
523
d
gm
Mineral
15-4
17-7
18.1
24.4
10.6
17.1
32.2
(ym)
Coal
13.8
17.3
21.1
28.2
13.2
15.5
34.5
a
9
Mineral
2.42
2.27
2.40
2.59
2.33
2.33
2.51
Coal
2.21
2.34
2.60
2.61
2.60
2.30
2.64

.Mine operation:
 Mine operation:
 Mine operation:
hauling, dragline, dressing,  scraping,
dragline only.
haul ing only.

-------
      For samples 5N through 8N collected on August 1, in which the mine
 operations consisted of coal hauling, dragline overburden removal,
 dressing and topsoil scraping, d   values for both mineral and coal
 particles are reported in the taBTe to be highest at ground level  (0.5 m
 elevation) and successively decrease, as would be expected, for samples
 taken at elevations of 10, 20 and 75 meters.  The vertical profile of
 d   for mineral and coal  particles sampled on August 1  appears to follow
 an exponential type relationship.  For samples 17N and  20N collected on
 August 5 (at the same balloon launch location as that of August 1),
 during which time the only mine operation was overburden removal  by the
 dragline, d   values are again highest for the ground level sample
 versus the 9§ meter sample.   The ground level d   values for mineral and
 coal  on August 5 are considerably less than those of August 1  but this
 is reasonable when one considers, besides the reduced mining activities,
 that  the topsoil scraping operation of August 1 occurred approximately
 100 m closer to the balloon  launch site.   The fact that  coal  particles
 were  present in concentrations comparable to the mineral particles on
 the August 5th samples is interesting.   The source of this coal  may
 have  been the pit itself, assuming that the dragline was removing over-
 burden near the coal seam, or from the storage coal  pile.

      Dust from a haul  road was monitored  only at an  elevation  of  30 m on
 August 6 (sample 4lM).  The  sampling occurred at a considerably  shorter
 downwind distance from the source than  on either August  1  or August 5
 (see  Figure 2).   Here  d   values  for mineral  and coal are  significantly
 greater at the 30 m elevation than those  measured at  ground  level  on the
 previously reported sampling  days.   In  addition,  the  total  number of
 coal  particles  observed on the 41M micrographs  was almost  four  times the
 number of mineral  particles.   This  is  probably  because some  coal  often
 spilled from the haul  trucks  at  the haul  road curve.  This  coal would
 become crushed  and  entrained  into the air by  trucks  passing  by  later.   In
 all instances,  d   values  of  mineral  versus  coal  are  comparable at  the
 same  elevations.

      The  average of all geometric standard deviations reported  in Table  1
 is  2.A3 with  a  corresponding  "standard deviation" of  0.14.  This  shows
 good  agreement  in the data such that all  of the  samples  are believed  to
 be  from the  same  general population of particles.

     All  of  the  cumulative mass distribution  plots of Figures 6,  7  and 8
 show a  characteristic  inflection  point in the vicinity of particle
diameters from  10 to 15 ym.  This may be attributable to the fact that
 the 80x and 6*»0x magnifications were sufficiently far apart that minimal
overlap occurred  in  the area where the two magnifications were least
accurate.

     Differential mass distributions for the sampled mineral and coal
particles are presented in Figures 8, 9 and 10.  The graphs are log-log
plots  of  the mass per interval divided by the difference of the log D
 interval boundaries  (ug/m ) versus particle diameter  (ym).   The data
points have been joined by smooth curves using a spline  fit routine.  It
 is apparent that the mineral  plots are more well behaved  than the coal
                                      54

-------
         SRMPLE 5N  MJNERRL
                                          SRMPLE 5N CORL
  1980
Q
en
o
\
£
"O
   100
    ie
                                    10030
                                  1000
                               Q
                                at
                                o
                                \

                                •o
                                   100
                                    10
                  10

            D  (microns)
                           100
                          IS Meter Elevation
               10

         D  (microns)
                                                    100
         SRMPLE 8N  MINERRL
                                          SRMPLE  8N CORL
  1000
a
a)
o

•o

£
-o
100
    10
                                  1000
                                Q
                                O)
                                o
                                £
                                TJ
100
                                    10
      10

0  (mlorons)
                              100
                                                  10

                                            D  (microns)
                           100
                          0.5 Meter Elevation
        Figure 9-  Differential mass distributions for mineral and coal

                 particles sampled at two elevations on_August 1, 1979.

                 (The unit of the ordinate axis is yg/m ).
                                 55

-------
        SRMPLE i?N MINERRL
  10000
   1080
Q
OB
O

•o

r
100
    10
                   J_
                                          SRMPLE  17N CORL
                                 10000 i '           i'
                                  1000 -
Q
0»
O

13
\
X,
100 -
                  10

             D (micron*)
                           100
                          75 Meter Elevation
                  10
            D  (microns)
                          100
        SRMPLE  28N  MINERRL
 10000
  1000
Q
09
o
•a

r
•o
100
    10
                                 10000
                                         SflMPLE 20N  CORL
                                  1080  -
                               Q
                                09
                                O
   100  -
                                        1
                  10

            D  (micron*)
                           100         *



                      0.5 Meter Elevation
                 10

            D (microns)
                          100
      Figure 10.  Differential mass distributions for mineral and coal
                particles sampled at two elevations on,August 5, 1979,
                (The unit of the ordinate axis is yg/m ).
                                56

-------
plots.  This can be attributed to the fact that in general, except for
sample **1M, 50 percent fewer coal particles were observed on the micrographs
compared to mineral particles.  The distributions show that the majority
of mass for both mineral and coal sampled at any elevation is associated
with the larger particles.  Note that tethered balloon sampling was conducted
with open faced filters such that nonisokinetic sampling took place in
which the filter face velocity was normally considerably less than the
mean wind speed.  This has undoubtedly biased the samples to some extent
with large particles.  Still, as expected, the vast majority of the
captured dust particles from the mining activities were in a coarse size
range of greater than 2 ym in actual diameter for all samples.

                              Soil Sample Analysis

     To determine the major crystalline mineral composition of the
selected soil samples, each sample was first pulverized, by means of a
ball mill, to fine material which would pass through a 200 mesh screen.
The powder samples were then semiquantitatively analyzed by a Philips X-
ray Diffractometer.  Diffraction spectra were obtained using copper ka
x-rays from 2° to 6^° 26.  Minerals were  identified by peak position and
semiquantified by comparing peak intensities to those of other known
mineral samples.  The results of this analysis are presented  in Table 2.

                            Time Lapse Movie Analysis

     Time lapse movies have been analyzed to confirm the downwind distances
of the tethered balloon sampling system from mining operations and to
establish the types and levels of activities occurring at the mine site
during sampling.  An example of the  information obtained concerning mine
operations for one day  is presented  in Table 3.  The time lapse photography
was also useful in documenting the relative amount and vertical extent
of dust from the various mine operations and in qualitatively assessing the
effectiveness of watering to suppress dust from active haul roads.  During
hot dry afternoons, haul road watering markedly reduced the amount of
visible dust from the roads for periods of 30 to kO minutes.

                                   CONCLUSIONS

     The tethered balloon sampling method, coupled with microanalysis,
can provide useful definitive insights into the nature of multispecied,
size discriminate particulate dispersions from fugitive dust sources.
The sampling method permits rapid horizontal and vertical mobility and
simultaneous sample collection at selected elevations and distances
downwind from dust sources with relatively little expense.  Optical and
electron microscopy provides useful estimates of particle size distributions,
concentrations and composition of lightly loaded samples.  This investigation
concludes that the tethered balloon sampling method can extend the exposure
profiling technique to more fugitive source sampling applications.

     Dust samples collected from the plumes of various strip mine operations
follow a log-normal  distribution.  Sampling at various elevations downwind
                                      57

-------
Table 3.  Mine Site Activities on July 31,  1979


Time
of
day
(hrs)
0730


0800



florin
U jUU
1000




1100




1 200



t 300
















Win
Oir
from






W






























- E
- W

— t
_ W
N

W
- E


- E
_ W
- E

- W





- E
1
J
Eu

E




)ragl in
Iperat i






0836
up

-0
d

*36
3wn
i
_I010
walk
-1030
up








-1123
down
1

1

1232
up
















.


















Total Number of
Passes
Topsoil Scrapin
Operation

1 umber o
Scraper
Passes





t
fc
4-
t
13
J
t
1
30
i
J


t
1
28
1
1
—





16
1
T
1


1
16
i
1
t
28
i
1

159


Time o
Water in
Trucks







- '0855
- 0?42



_ 1029




-1114











-1348

-1426


-1506


-1553



- 1648

9

E-W Haul Road L
Truck Traffic
4umL
\«r
Haul
Truck
Passes

17
30



T
t
!
3&






!
I




29


1
-
2

t
11
4





15
I



23
i
1
I
1



26
1
1
f



33

i



222



Time o
Waterin
Trucks



























1311
1323
1352
1356
1409
1413
1434
I44j
1451
14^4
1515
1518
1531




1633
1652

16



Other
Activities







0836-0842
Cat dressed crushed
coal pile
0836-1140
;oal loading south end
of pit A
OS34-1006
:at dressed dragline
>ase area

Charge dri 1 1 rig in
operation all morning
;at dressed south end
of O.B. pile (W of
).L.) all morning
0«36-1045
1136-1216
Cat dressed O.B. dri 1 1
area (E of D.L.)

232-154"
Cat dressed O.B. pile
^W of D.L.)

1331
Coal blast in Pit A
1232-165?
Cat dressed O.B. drM
area (E of D.L.)
Charge dri 1 1 rig in
operation all after-
noon

1405 to end coal
loading south end of
Pit A

1232-1300
1405-1558
i £oc i tnt\
1O25-17''1'
Cat dressed D.L. base
area

1658
O.B. blast




Remarks



_0745
Start of balloon
sampling operation
0836
Start of time
lapse movie-Rol 1 2

Winds light all
day steady from W
until 1155 then
extremely variable
Balloon samples
taken near CSU
stakes 17 & 1«









1216
End of Roll 2
Start of Rol 1 3


-1321
Clock blown over-
event times calc.
from frame f

1412
End of bal loon
sampl ing operation









65"
nd of Roll 3


                    58

-------
Table 2.  Soil Sample Analysis
Mi neral
Quartz
Feldspars
Do 1 om i te
Calci te
Kaol ini te
Plagioclase Feldspar
Montmori 1 loni te
Sampl
Haul Road Drill
Major
Minor
Trace
Trace
--
Trace
--
e Composition
Hole Spoi Is
Major
Major
Major
Mi nor
Trace
Trace
—

Overburden Pile
Major
Minor
Minor
Minor
Trace
Trace
--

aMajor - >_ 25% of sample.
Minor - distinct portion of sample (5~25%).
Trace - slight peak present (~ < 5%).
- absent from sample (~ < 1%).
              59

-------
 of mining activities has demonstrated that the mass media diameters
 of mineral and coal particles decrease with increasing sampling height.
 Still, considerable dust concentrations are present at a sampling height
 of 75 m and a significant fraction of this dust consists of particles
 having diameters greater than 10 ym.  The large particles are responsible
 for the major mass fraction of all samples.

      Time lapse photography has been shown to be a useful technique to
 document balloon sampling operations and surface mining activities.
 This technique can be applied to visually assess the effectiveness  of
 dust control  measures and strategies.

                              PLANNED ACTIVITIES

      Tethered balloon sampling at higher elevations and over a  wider
 range of downwind distances will  be conducted  at surface mines  to more
 accurately determine the vertical extent and  downwind transport of
 fugitive dust plumes.

      A series of balloon systems  will  be utilized in conjunction with
 the exposure  profiling  technique  to establish  improved emission factors
 from mining and other fugitive emission  sources.   Typical  sampling
 schemes employing four  balloons are presented  in Figures  11  and 12.
 When sampling a line source,  such as the haul  road shown  in  Figure  11,
 it  is envisioned that  the three downwind balloons will  be aligned parallel
 to  the prevailing wind.   This  network  will allow the downwind dust
 transport  to  be evaluated as well  as the validity of extending  the
 exposure profile technique to  greater  sampling  distances.  The  characterization
 of  emissions  from point  and area  sources  will  require a  two  dimensional
 sampling network,  such as  that  shown in  Figure  12.   As with  the line
 source sampling scheme,  an  upwind  balloon will  be operated to determine
 background dust concentrations.

      Basic improvements  to  the wind  vane  particle samplers are  also
 planned. Elutriators  will  be added  to the samplers  to allow for  the
 sampling of inhalable particles having an aerodynamic diameter  of 15  ym
 or  less.10  Inhalable particles can  further be  subdivided  into  groups of
 coarse  and fine  fractions with a  cut point being  approximately  2.5 ym.
 The  fine particles are primarily  responsible for  air  quality visibility
 degradation and are  primarily produced by combustion  processes.   The
 coarse  fraction of  inhalable particles are those  between  2.5 and  15 ym
 and are  normally  classified as mechanically generated.  Most wind generated
 dust,  for example, would consist of  coarse size particles.  Depending on
 the  type of source being sampled,  it may  sometimes be desirable to be
able  to  separate  inhalable particles into coarse  and  fine fractions.
 For example,  fugitive particulate emissions from  an  iron foundry are
expected to be a mix of fine and coarse particles.   By being able to
quantify the  fractions in  terms of amount and chemical composition,  the
actual emission sources should be able to be identified.  When desired,
the balloon samplers will employ sequential filtration to separate
 inhalable particles  into coarse and  fine fractions.11
                                      60

-------
 LAYOUT OF TETHERED BALLOON SAMPLING SYSTEM FOR PROFILING THE PLUME
 FROM A LINE SOURCE AND FOR DETERMINING THE DOWNWIND TRANSPORT OF PARTICLES.
                     Figure 11
LAYOUT OF TETHERED BALLOON SAMPLING SYSTEM FOR PROFILING THE PLUME
FROM AN AREA SOURCE.
                     Figure 12
                         61

-------
                                    REFERENCES

 1.    J.  A.  Armstrong and P.  A.  Russell,  "The Monitoring  of Participates
      Using  a  Balloon-Borne Sampler," in  Symposium on the Transfer  and
      Utilization  of Particulate Control  Technology,  Volume 4,  EPA-600/7-
     79-044d, (NT1S PB 295229),  February  1979, pp.  357-376.

 2.    J.  A.  Armstrong, P.  A.  Russell,  M.  N.  Plooster  and  L. E.  Sparks,
      "Tethered  Balloon Plume Sampling of a  Portland  Cement Plant."  To
      be  submitted for publication.

 3.    J.  S.  Evans, D.  W.  Cooper,  M.  Quinn and M.  Schneider, "Setting  Prior-
      ities  for  the Control of Particulate Emissions  from Open  Sources,"  in
      Symposium  on the Transfer  and  Utilization of  Particulate  Control
      Technology,  Volume  4, EPA-600/7-79-044d (NTIS PB  295229),  February
      1979,  PP 85-103.

 4.    W.  D.  Scott  and  C.  E. Bates, "Measurement of  Iron Foundry  Fugitive
      Emissions,"  in  Symposium on Fugitive Emissions:  Measurement  and
      Control,   EPA-600/2-76-246  (NTIS  PB 261955),September 1976, pp  211-237.

 5.    R.  N.  Lindstrom  and  S.  E.  Sundberg,  "Fugitive Particulate  Emission
      Rate and Characterizatfon  for  Electric  Arc  Steelmaking Furnaces,"
      presented  at the 72nd Annual Meeting of the Air Pollution  Control
      Association,  Cincinnati, Ohio, 79-39-3,  1979.

 6.    P. W.  Kalika, R.  E.  Kenson  and P. T. Bartlett, "Development of
      Procedures for the Measurement of Fugitive  Emissions," EPA-600/2-76-284
      (NTIS  PB 263992), December  1976.

 7.   F. J. Miller, D.  E. Gardner, J. A.  Graham, R. E. Lee, W. E. Williams,
     and J.  E. Bachmann, "Size Considerations for  Establishing a Standard
     for Inhalable Particles," APCA Journal,  29_:6, 1979.

8.   C. Cowherd, C. M. Maxwell and D. W.  Nelson, "Quantification of  Dust
     Entrapment from Paved Roads," EPA-450/3-77'072 (NTIS PB 269944),
     July 1977.

9.   J. D.  Stockham and E. G. Fochtman,  Particle Size Analysis, Ann Arbor
     Science,  Ann  Arbor, 1977, P. 6.

10.   W. B.  Smith,  K. M. Cushing, M.  C. Thomas and R.  R. Wilson, "Some
     Aerodynamic Methods for Sampling Inhalable Particles," in Proceedings:
     Advances in Particle Sampling and Measurements,  EPA-600/9-80-004
     (NTIS PB 80-187487), January 1980, pp.  316-347.

11.   T. A.  Cahill, L. L.  Ashbaugh,  J. B.  Barone,  R. A.  Eldred,  P.  J.  Feeney,
     R. G.  Flocchini, G.  Goodart, D. J. Shadoan and G.  W. Wolfe, "Analysis
     of Respirable Fractions  in  Atmospheric  Particulates  via Sequential
     Filtration,"  APCA Journal,  27;7, 1977.
                                      62

-------
            Appendix A.   Sampling  Log  of  Selected  Balloon  Operations
Date
8/1/79



8/5/79


8/6/79
Filter
Number
05N
06N
07N
08N
17N
18N
19N
20N
41M
Sampl ing
Elevation
(m)
75
20
10
0.5
75
20
10
0.5
30
Start
Time
(hrs-MDT)
0659
0708
0711
0720
0828
0830
0835
0848
1155
Total
Time
(min)
283
269
264
263
408
?
265
372
165
Air Vol.
Sampled
(&) Remarks
778
740
317
421
1122
? Pump stal led
during sampl ing
318
595
553
Note:  Launch sites shown on Figure 2.
                                       63

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               PARTICLE PRODUCTION FROM  SURFACE MINING:  PART 2

              SURFACE PARTICULATE AND METEOROLOGICAL MEASUREMENTS

                               David L.  Dietrich
                           Colorado State University
                            Fort Collins, Colorado
                              William E. Marlatt
                           Colorado State University
                            Fort Collins, Colorado


                                Douglas G. Fox
               Rocky Mountain Forest & Range Experiment Station
                            Fort Collins, Colorado

     Federal land managers are now being challenged to evaluate the scope of
potential environmental effects in the development of western mineral
resources.  The influence that surface mining for coal will have on air quality
is one impact that must be considered.  This paper describes the first phase
(summer 1979) of a study to investigate the sources, characteristics, and
transport of particulate emissions from surface mining.  Air quality and
meteorological measurements were made on a surface mine in western Colorado.
Near source suspended and deposited particulate loads were quantified as they
relate to meteorological conditions and mining operations.  The results char-
acterize the variety, variability, and complexity of particulate emissions from
mining operations in the western states.  The study provides the basis for a
continued research effort (Phase II) to be conducted in the summer of 1980.

-------
                                 INTRODUCTION
     There is an Increasing demand for coal in the United States.  A large por-
tion of our coal reserves exist on federally managed land in the semi-arid
regions of the western states.  Federal land managers are now being challenged
to evaluate the scope of potential environmental effects in the leasing and
development of these western energy resources.  The influence that surface
mining for coal will have on air quality is one impact that must be considered.

     Most air quality regulations that apply to surface mining are still unre-
solved.  The Environmental Protection Agency (EPA) has proposed regulatory
procedures (44 FR 51924, September 5, 1979) that alter their previous exclusion
of fugitive dust from prevention of significant deterioration (PSD) review.
Fugitive dust is defined as particles of native soil uncontaminated by pollu-
tants resulting from industrial activity.  The proposed EPA procedures now
state that fugitive emissions should not be considered in determining air
quality degradation except for 26 named source types.  The procedures also
state that the Administrator of the EPA will consider the need for additional
source types, including surface mining, over the next few months.  However,
even when fugitive dusts are excluded they cannot be ignored.  Proposed regula-
tions point out that:  1) the applicant must determine the amount of total
emissions that are fugitive dust; 2) mines emitting greater than 250 tons/year
(225 metric tons/year) including fugitive dust must apply best available con-
trol technology; and 3) the fugitive dust exclusion will be reviewed periodi-
cally by the EPA.  In addition to EPA regulations, the Office of Surface Mines
and most states also consider air quality in their regulations.

     Despite these regulatory clarifications and exemptions, the federal land
manager remains challenged with making environmentally sound, resource related
decisions.  These decisions may be affected by the lack of knowledge about the
sources, nature of particles, and transport of all emissions from surface min-
ing, including fugitive dust.

     The purpose of this study is to conduct field research on the sources,
nature of particles and transport of air pollutants from surface mining.  The
study is funded by the Bureau of Land Management and is being performed in com-
bined effort by the U.S.D.A. Forest Service, Rocky Mountain Forest and Range
Experiment Station and Colorado State University.  The broad goal of the study
is to provide insights into the nature and magnitude of air quality impacts
that federal land managers must consider.  The study is being conducted in two
phases over a two year period.  Phase I, performed during the summer of 1979,
emphasized near-source analysis of surface mine emissions from a test site in
western Colorado.  Phase II, to be conducted in 1980, will emphasize analysis
of air quality at various upwind and downwind distances from the surface mine.
This paper discusses the preliminary results from the Phase I field program.
                                      65

-------
                                    BACKGROUND
      In most of the non-industrialized arid west, air quality and visibility
 are dependent on the amount of native or fugitive dust in the air.  The dust is
 emitted by human activity and wind erosion of undisturbed and disturbed lands.
 The more people, agriculture, mining or other activity, the greater the amount
 of dust released into the atmosphere.  In addition, the increasing number of
 industrial sources, such as coal fired power plants and mineral processing fa-
 cilities, is influencing air quality.  What, if any, contribution surface min-
 ing emissions have on local or regional air quality can not be easily deter-
 mined.   The wide variety of pollutant sources associated with mining areas such
 as mine mouth power plants, boom-town growth, and increased traffic make iso-
 lating the pollutant contribution of a surface mine even more difficult.
 Measurement techniques to quantify and separate each of these sources to evalu-
 ate their respective impacts are limited, varied, and complicated.

      This study was not designed to address or answer all of the air quality
 problems of the west,  but was designed with four major objectives:

      1.  determine the sources and quantity of particulate emissions from
          surface mining;
      2.  determine the physical and chemical nature of the emissions;
      3.  determine the background particle loading,  deposition,  and visibility
          in semi-arid  regions of the west;  and
      4.  develop and validate various particle sampling technologies.

      The overall goal  in  addressing these objectives is to provide information
 related to the  decisions  federal land managers face  in leasing and managing  our
 nation's mineral-rich  western land.

      To accomplish these  objectives,  a two  phase  field program was developed.
 Phase I,  conducted during the summer  of 1979,  emphasized  the  characterization
 of  particulate  emissions  near the broad range  of  sources  in a surface mining
 operation.   Field  measurements  were taken on an active surface mine  during two
 periods (June 4-7  and  July 30-August  7, 1979).  Along with the measurements tak-
 en  by the  Colorado  State  University/Rocky Mountain Forest  and Range  Experiment
 Station team, the  study site  was  shared with independently supported research
 teams from the Denver  Research  Institute  and the University of Minnesota.  In
 addition to  the  on-site mine  activities,  Phase I work  also established an
 atmospheric  deposition station  and a visibility monitoring station.  The depo-
 sition  station is operated as part of  the National Atmospheric Deposition Net-
work.   Visibility measurements will be used in analyses that will  attempt to
 consider the effects of fugitive  emissions on atmospheric visibility.

     Phase II, to be conducted during  the summer of  1980, will emphasize the
measurement of atmospheric particulate loading at increased upwind and downwind
distances  from the  surface mine.  The measurements from both phases will be
combined and applied to evaluate  transport mechanisms and to estimate what, if
any, effect particulate contribution from mining may have on local and regional
air quality.


                                       66

-------
                             PHASE T FIELD PROGRAM

                                The Study Site
     A fully operational surface coal mine served as the study site.   All asso-
ciated mining activities cover an area of approximately four square miles
(10.3 km2).  The topography of the region is rolling terrain with an average
elevation of approximately 6,500 feet (1,980 m).   The mine was located on a
gentle, north facing slope.

     Weather plays a major role in the emission and transport of fugitive dust
in the arid west.  The study site is located in a region that receives a year-
ly average of 13.5 inches (34 cm) of precipitation.  Precipitation is distri-
buted evenly throughout the year.  Winters are cold and windy and light snow
cover is often present.  In the summer months, intense solar radiation, per-
sistant winds and low relative humidity contribute to hot and dry conditions,
providing an environment for maximum fugitive dust emissions.

     Land use in the region includes dryland agriculture (primarily winter
wheat) and livestock grazing.  Native vegetation is sparse and dominated by
sagebrush.

                              Particulate Sources

     The sources of particulate emissions from the mine include:

          dragline operation            grading
          coal loading in pit           haul road traffic
          drilling                      coal storage pile dressing
          overburden blasting           coal crushing (only during June 4-7)
          coal seam blasting            loading from storage pile
          top soil scraping

     The emissions generated from each source are dependent on wind speed,
moisture, type of equipment, and scheduled time of the activity.  The nature
and strength of the source can be affected by a wide range of circumstances.
For example, a haul truck that is slightly overloaded can spill a portion of
its load while rounding a corner.  Subsequent haul trucks will crush and en-
train the spilled coal into the atmosphere.  Under these circumstances, a haul
road, normally a source of primarily fugitive dust, will become a source of
coal particulates until a road grader cleans and dresses the haul road.  With
these intricate variations in sources and source strength, isolating individual
particulate sources in an operating coal mine is extremely difficult.  There-
fore, throughout the analysis of Phase J. data, no attempt was made to calculate
the emission factor of any individual particulate source.

     Two short-term field programs were conducted during the summer of 1979
(July 4-7 and July 30-August 7).  Hot, dry, and often windy conditions coupled
with all mining operations being in full swing provided an environment where
maximum particulate emissions could be expected.  If measurements were taken in
the winter or wet spring^ very different results would be expected.

                                       67

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                                 Instrumentation

      The need to measure particulate emissions from complicated area sources
 such as a surface mine has stimulated the technical imaginations of many a
 researcher.  The instrumentation used in Phase I employed both standard and
 imaginative technology.  The primary sampling strategies used on the mine site
 included active and passive particulate measurements and meteorological mea-
 surements.  Off-site measurements were taken of atmospheric deposition and
 visibility.  Though associated with the study, these off-site measurements are
 also committed to other research goals.

 Active Particulate Samplers

      1.  High Volume Samplers:  Two high volume samplers (hi-vols)  were operat-
 ed during both Phase I field programs.   The hi-vols were located approximately
 100 and 150 meters from a major particulate source area.  For the June program
 the hi-vols were operated with standard filters.   During the July-August pro-
 gram,  the hi-vols were outfitted with Andersen Head particle size samplers in
 order  to obtain information about the particle sizes contributing to the near
 source air quality.   Due to the location of the hi-vols, the particulate load-
 ing they monitored was probably dominated by haul  road  traffic  and  coal stor-
 age pile activities.   A schematic showing the location  of the hi-vols and other
 on-site instrumentation relative to the location of mining activities is pre-
 sented as Figure 1.

     2.   Wind Erosion Threshold Velocity Measurements;   As part  of  the June
 sampling program,  a  portable wind tunnel,  operated  by Dr.  Dale  Gillette
 (National Center for  Atmospheric Research),  was used to  determine the threshold
 wind velocities required to erode a variety of  surfaces.   Analyses  were per-
 formed over freshly dressed and weathered  coal  storage piles, dry and wetted
 haul roads,  wheat  fields,  spoil piles,  graded  reclamation areas,  native cover,
 and other surfaces.   Analysis of the data  will  highlight the erodability of
 various  stages  of  disturbed land and coal  storage as compared to  undisturbed
 a*nd agricultural  land.

     3.   Elemental Analysis;   As part of  the July-August  sampling program, a
 spatial  and  temporal  variety  of  particulate  samples  were  taken by Dr.  Thomas
 Cahill  (University of California, Davis)  for elemental analysis.  Samples  taken
 both upwind  and downwind from the mine will be  analyzed  for  their chemical and
 physical  characteristics.

     4.   Balloon-Borne Particulate  Samples;  In a separate project,    Dr. James
 Armstrong and his associates  from the Denver Research Institute collected par-
 ticulate  samples throughout the  study area via  a balloon-borne sampler.  The
 results of their research are  presented in the preceding paper of this  sympos-
 ium.

     5.  University of Minnesota Mobile Laboratory;  During the summer of 1979
 Dr. Virgil A. Marple  and his associates were conducting air quality experiments
 throughout the southwest as part of  the U. S. Environmental Protection Agency
VISTTA visibility research  program.  In support of both EPA and Bureau of Mines
 funding, the University of Minnesota took advantage of the July-August sample

                                      68

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               Native Shruh

    Agrlcu
SCALE
                                                   Blow-Up
                                                   I	
                                             FIGURE  1
                       LOCATION OF  INSTRUMENTATION  AND MINING ACTIVITIES

-------
 period to investigate surface mine emissions.   The instrumentation in the
 mobile laboratory was capable of making fast  response measurements of the chem-
 ical and physical nature of particles,  particle transport  and visibility.   The
 mobile laboratory permitted specific monitoring of individual emission sources.

 Passive Particulate Samples

      1.   Petri Dish Dust Fall Network:   Dust  fall  collectors  were  fabricated
 for  the study.   Each collector consisted of a  standard petri  dish  equipped
 with a dust  catchment media (astroturf).   Each dish was mounted  at 0.5 meters
 above the soil.   Dust fall  was collected over  a one day period in  June and
 over two four-day periods in the July-August program.   Collected dust fall was
 weighed and  converted to dust fall rates (g/m2 day).   Dust  fall  samples were
 also qualitatively analyzed for the amount of  coal, and, during the June field
 program» for presence of  seeded tracer material.

      A 60 dish network was  established  for the June field  program.   The dis-
 tance between  dishes was approximately  60 meters.   The network was expanded to
 120  collection sites for the July-August  program.

 Meteorological  Measurements

      1.   Tethersonde;  A tethered helium balloon with an instrument package was
 used to  measure  verticle profiles of  wind, temperature,  and humidity.   These
 soundings were  generally taken three  times per day (early morning,  noon and
 early evening).   On  the  average, the soundings  extended from the  surface to 450
 meters.

      2.   MRI Weather Stations;   Wind  speed, wind direction and temperature
 were monitored  continually  by MRI weather stations.   One station was  located
 near the  meteorological  tower and within  the dust  fall network.  Measurements
 taken at  this  station  are representative  of the local  meteorology  within  the
 major sampling  area.   A  second MRI station was located at a topographic high
 point  overlooking  the  mine  and was considered  more representative  of  the
 synoptic  flow.

      3.   Atmospheric Turbulence  Measurements:  A 15 meter tower  was erected
 near  the  center  of the data  collection activities.  Three sets of  Gill  (u,v,w)
 anemometers were placed  at heights  1, 3, and 15 meters on the  tower.  The
 instrumentation was  connected  to  an automatic  data logging system  that  record-
 ed instantaneous signals from the  anemometers  for  2.5  minutes  each hour (at a
 rate  of three scans  per  second).   The data will be used  to evaluate the nature
 of atmospheric turbulence at  the  field site.

 Off-Site  Instrumentation

      1.  Atmospheric Visibility  Site;  Daily visibility measurements  started
 in April  1979 and continue  to  date.  Two different instruments are used, a
 contrast  telephotometer  and an  integrating nephelometer.  The visibility site
overlooks  the mine and is located  on a hill top approximatly ten kilometers
 from the mine site.  The telephotometer is aimed at four different distance
 targets once each day at mid-morning.  The mine site is  located between the
telephotometer and one of these  targets.  The nephelometer runs continuously
sampling local air.


                                      70

-------
                            RESULTS AND DISCUSSION

     Preliminary results from the first phase (summer 1979)  highlight a number
of interesting observations pertaining to the sources, nature,  and transport
of fugitive emissions from surface mining.   Emission sources at the mine in-
cluded a complex array of point, line, and  area sources.   The primary study
area concentrated on emissions generated in the vicinity of  the pit and coal
storage pile.  A primary haul road in this  vicinity appeared to be a major
contributor to the particulate loading of the local atmosphere.  The following
observations and results were recorded by the various instrumentation utilized
in the June and July-August sample periods  of Phase I.

                          Active Particulate Samples

     High volume sampler results indicate that the total suspended particulate
concentrations, near the mining and coal handling operations were quite high
(200 - 1000 yg/m3) and well above the background (annual average approximately
40 yg/m3).  However, indications are that groundlevel air concentrations de-
crease rapidly downwind from the sources.  Due to the location of the hi-vols
and frequency of wind direction, the majority of the dust collected by the hi-
vols was probably generated from coal storage pile and haul  road activities.
On the average, total suspended particulates measured at the hi-vol located
150 meters from the haul road and edge of the coal storage were 33 percent
less than measured at 100 meters.  During the July-August sampling periods,
Andersen Head particle sizing plates were operated on the hi-vols to provide
information on the particle size distribution of the suspended particulate
loads.  Results indicate that approximately 35 percent (be weight) of the par-
ticles sampled were above 7 ym and 35 percent (by weight) of the particles
were below 1 ym.*  Table 1 presents the hi-vol measurements  for the July-
August sample periods.  Figure 2 presents a representative sample (August 6-7
measurement) of Andersen Head particle size distributions.

     Analyses of the wind erosion threshold velocity measurements and elemental
analysis are continuing.  Therefore, the results are not available for this
report.

                          Passive Particulate Samples

     The dust fall network provided the opportunity to observe how deposition
rates vary with distance from the mining operations.  Rates  as high as
25 g/m2-day were recorded immediately adjacent to haul roads, but usually
within 600 meters of a source the rates had dropped to less than 1 g/m2-day.
Topography, meteorology, and mining activity had an effect on the deposition
pattern.  An example plot of dust fall rates for the July 30-August 3 period
is presented as Figure 3.  In addition to total dust fall two other qualita-
tive analyses were performed on the dust fall samples.  The amount of coal  in
the dust fall sample relative to the amount of non coal dust was estimated  for
each sample.  Results indicated that coal amounts were highest around the coal
storage pile, near a haul road turn where coal was being spilled from haul
trucks, and immediately downwind from the pit (perhaps due to coal seam
*It should be pointed out that size separation was accomplished using the
standard hi-vol sampler.  No 15 ym cyclone cut-off device was used; therefore
the sample may be somewhat biased to the smaller particle sizes.


                                       71

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           TABLE 1
       HI-VOL  RESULTS
(24 Hour  Samples at  1200 MDT)




Dace
7/30-7/31

7/31-8/1


8/1-8/2


8/3-8/4


8/4-8/5



8/5-8/6



8/6-8/7






(meters from
major sources)
150
100
150
100

150
100

150

100
150

100

150

100

150

100

Particulate Concentrations in ug/m3 and Percent
Anderson Head Results
(Plate No. and 50% Cutof
1-1
(7 ura)
-
-
_
176
(4C.7)
_
84
(19.4)
199
(41.2)
-
113
(40.8)
197
(31.6)
77
(37.9)
102
(24.6)
191
(51.1)
264
(36.5)
2-3
(3.3 urn)
-
-
_
5]
(11.8)
_
43
(9.9)
65
(13.5)
-
39
(14.1)
78
(12.5)
£9
(14.3)
43
U0.4)
54
(14.4)
93
(12.9)
3-4
(2.0 urn)
-
-
-
29
(6.7)
_
33
(7.6)
46
(9.5)
-
33
(11.9)
58
(9.3)
25
(12.4)
23
(5.5)
48
(12.8)
78
(10.8)
: Dla. in urn)
4-5
(1.1 um)
-
-
-
23
(5.4)
_
14
(3.3)
28
(5.8)
-
22
(7.9)
44
(7.0)
10
(4.9)
13
(3.1)
25
(6.7)
44
(6.1)
Back-up
(<1 urn)
-
-
-
153
(35.4)
-
259
(59.8)
145
(30.0)
-
70
(25.3)
247
(39.6)
62
(30.5)
234
(56.4)
56
(15.0)
244
(33.7)


Total
Particulates
Equip. Fall.
Equip. Fail.
Equip. Fail.
432

262
433

483

916
277

624

203

415

374

723

              72

-------
                                FIGURE 2

                       SURFACE MINE EMISSION STUDY
               HI-VOL SUSPENDED PARTICULATE CONCENTRATIONS

                    AND ANDERSON HEAD PAUTICLE  SIZE
  1000
bl
 i
W
K
u

§
1 i

H
, i

i:
11
W

n

900

800
700
600
500
400

300

200
100
D


DATE: 8/6 -
TIME: 1200
- 8/7
- 1200
|//yf 150 m HI-VOL
| 	 1 100 m HI-VOL






















7/
//
/
;-:
XXXXX^I


—

k\\\\XX








ibi fb rb5








K
   Total      >7.0

Particulates   pm
3.3-7.0  2.0-3.3

   um        iim
                                                     1.1-2.0
                                                                   1 1;
                     ANDERSON HEAD PARTICULATE SIZE RANGES (\im)

-------
                                   FIGURE  3

                            DUST  FALL  DISTRIBUTION

                               7/30/79  - 8/3/79
Relative
Wind Rose
   -. -> - —

          ,
          j
          lw>
          $££
           >6
           ^

         :"--
       SCALE
                                     ; ,

-------
blasting).  A plot of the amount of coal in the dust fall samples for the
July 30-August 3 period is presented as Figure 4.

     During the June sampling period coal haul roads were seeded periodically
with a florescent particle tracer.  When a truck would pass over the haul road
the particles would become entrained and later fall out on the dust fall net-
work.  The amount of tracer material found in the dust fall samples during
analysis correlated well with the wind direction.  The tracer provided confi-
dence that the dust fall network was sampling material generated from mining
activities.

                          Meteorology Measurements

     Daily wind roses were plotted throughout the sample periods.  Daytime
winds were predominantly from the west and northwest.  The orientation of the
topography appeared to channel the synoptic flow into westerly local flow at
the study site.  Strong, gusty winds often occurred between 1400 and 1600,
induced by local thermal convective cells.  At night, a downslope (southerly
flow) was often established.  Inversions occurred on most mornings and were
usually broken by 11:00 a.m.  The tethersonde soundings effectively illustrat-
ed a number of these inversions.  Figure 5 provides an example of soundings
at  7:00  and 12:00 on August 6.  Throughout the study periods, a number of
dust devils were observed.  These mini-cyclones would entrain and carry par-
ticulates to altitudes of hundreds of meters.

     Air turbulence data taken by the u,v,w anemometers is still being analyzed
and,therefore,will not be presented in this report.  When the analysis is com-
plete, the results will contribute to dispersion modeling exercises using data
collected during Phase I and anticipated data from Phase II.

                           Visibility Measurements

     The integrating nephelometer draws an air sample, passes a light through
the air sample and measures the scattering of the light.  It is possible to
relate the light scattering to visibility reduction by assuming that no light
is absorbed by the particles present in the air.  This assumption is expected
to be quite good for low concentrations of particles of soils.  Carbon parti-
cles obviously would be expected to absorb significantly, however, so that as
the percentage of carbon present increases, the  actual visibility degradation
might be greater than indicated by the instrument.  A major disadvantage of
the nephelometer is the fact that it takes a local, small air sample.  Obvi-
ously, if the atmosphere is homogeneous, then this small sample is representa-
tive.  For looking at long distances, especially in mountainous topography,
such a sample must be viewed as an indication of local conditions only.

     Generally, visibility is reported in terms  of visual range, defined as
the  longest theoretical distance that one can distinguish a target against a
background.  The theoretical limit to visibility is Raleigh scattering, namely
scattering by the air molecules totally free from any suspended aerosol.
Raleigh scattering suggests a visual range on the order of 390 km.

      Table 2  and Figure 6 provide summaries of the nephelometer data  taken  in
western Colorado  (10 km from the mine site) over an 11 month period.  Visual
ranges  vary  from a maximum of 377 km to a minimum of  36 km.  The interpretation


                                      75

-------
                                    FIGURE 4



                      QUANTITY OF COAL IN DUST FALL SAMPLE


                               7/30/79 - 8/3/79
Relative

Wind Rose
                                                      ;
                                                      •
                                                      !
                                                      i
                                                      i
                                                      i
                                                     i
                                                     •
                                                     >
                                                     •
                                                     •

                                                     g
 KEY:



       Light (0-33%)


¥777%  Medium (3A-66%)



       Heavy (>67%)

                                     76

-------
                           FIGURE  5

               TEMPERATURE, RELATIVE HUMIDITY AND
               WIND VELOCITY TETIIERSONDE SOUNDINGS
9VO-

MO


4OO

e
3100
I
100

too

0
DAT
TI;

t
i
1
1
j
1
I
^
\
{
Vs
"{
\
	 — • . -T-»— 1— — T ^
                                                 TEMP.
                                                 REL-
103O40
                  M   )•   IB   M  11
                TIMPtMATUflf I°C1

         9O   «O   TO   iO   00   WO
       HUMIDITY \\\
                                                                 WIHD SKID
                                                                 • DIM err OH
         PATE:  S/b/79
         TIME;  120O MDT
 •    •   M>   l>



MCLAftVf  HUMID) rr
                      M   l«   H    »   J>   »   !•  71   30  31
                                                                 WtHO SPtf D
                                                                 4 OinECtlON
                                  77

-------
                                  TABLE 2
                                NEPHELOMETER
                                Visual  Range
                                    (km)
Month/Year
4/79
5/79
6/79
7/79
8/79
9/79
10/79
11/79
12/79
1/80
2/80
Averag««
Max
166
307
377
207
280
278
279
311
329
316
327
289
Mln
69
81
81
86
74
58
93
70
46
45
36
67
Std. Dev.
29
45
49
27
43
45
40
56
59
58
71
-
Mean
107
158
151
134
175
141
160
169
124
137
153
146
                                  FIGURE 6
                            NEPHBLOMETER RESULTS
400
300
100-
                         78      9    .10     11
                              MONTH  (1979-80)
                                                      12
                                    78

-------
of these data, however, is not straight forward.   Visibility decreases and in-
creases from day to day for a great many reasons.  A longer record will be
needed in order to reach valid conclusions about  any effects of mining activ-
ity on visibility.  It is interesting to note one comparison with a telephoto-
meter observation; Malm, et al. (1979) presented  results from a number of lo-
cations.  One location, Dinosaur National Monument, in northwestern Colorado
could be considered to be in a visual environment similar to our study.  The
average visual range they measured for summer 1978 was 195 km and for spring
1979 was 169 km.  The mean value we measured for  spring 1979 was approximately
139 km, while summer 1979 was 150 km.  The comparison should not be inferred
to indicate anything other than the nephelometer at our site is indicating
visual ranges the same order of magnitude as at Dinosaur.

     Contrast telephotometer data taken over the  same 11 month period are
still being reduced, and are not presented in this report.
                                 CONCLUSIONS

     During the summer of 1979, Phase I of a two phase study was conducted to
evaluate the sources, physical and chemical characteristics, and transport of
particulate emissions from a surface mine in the semi-arid west.  The study
emphasized analysis of particulates near the emission sources within a working
coal mine.  A variety of air quality and meteorological instrumentation was
utilized to collect data during two sampling periods.  Results highlight the
temporal and spatial variability of emission sources relative to meteorologi-
cal conditions, type of equipment used, and type and scheduling of mining
activities.  Though this source variability complicates measurement and anal-
ysis of emissions, valuable information pertaining to the particulates that
mining contributes to air quality can be investigated.  Phase I field programs
were conducted during the dry summer months under conditions where maximum
fugitive emissions would be expected.  Particulate measurements taken during
the winter or wet spring would yield different results.

     The uniqueness of a surface mining site (topography, soils-spoils, local
meteorology, depth of coal seam, surrounding land use, and other factors)
coupled with the engineering decisions employed to extract, transport and
store the mineral resource, emphasize the difficulty in translating informa-
tion gathered at one mine to other mines.

     Phase II of this study will be conducted during the summer of 1980.
Phase II will emphasize the measurement of particulates at increased upwind
and downwind distances.  Results from both phases will be integrated to
thoroughly address the objectives and goals of the research effort.  Increas-
ing land disturbances and increasing numbers of industrial sources in the west
will increase the level of particulates in the atmosphere.  What, if any,
contribution surface mining will have on air quality and visibility is a par-
ticularly difficult question to answer, but one that should be pursued.  Land
managers must have information available to assist them in making environment-
ally sound decisions relative to the utilization of the nation's valuable
resources in the semi-arid west.
                                      79

-------
                                  REFERENCES
Environmental Research and Technology, A Comparison of Alternative Approaches
     for Estimation of Particulate Concentrations Resulting from Coal Strip
     Mining Activities in Northeastern Wyoming, Prepared for U.S. Dept. of
     Energy, Doc. P-3545-106, October 1979.

Gillette, D. A., "Fine Particulate Emissions Due to Wind Erosion," Transactions
     of the ASAE. Vol. 20, No. 5, pp. 890-897, 1977.

Malm, W. C., E. G. Walther, K. O'Dell and M. Kliene, Visibility in the South-
     west, Unpublished, 1979.

Marlatt, W. E. and D. L. Dietrich, Progress Report — Surface Mine Emission
     Study. U.S.D.A. Forest Service Contract No. 16-864-CA, Colorado State
     University, Fort Collins, CO, October 1979.

Zeller, K. F., D. G. Fox and W. E. Marlatt, "Estimating Dust Production From
     Surface Mining," Proceedings, Third Symposium on Fugitive Emissions.  1979.
                                      80

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          FUGITIVE EMISSIONS CONCERNS FOR COAL STORAGE AND HANDLING

                        AT UTILITY OPERATING STATIONS


           Presented at the Fourth Symposium on Fugitive Emissions:
                           Measurement and Control
                               May 28-30, 1980
                   Monteleone Hotel,  New Orleans, Louisiana

                     Peter W. Kalika and Pietro Catizone
                        TRC Environmental Consultants
                                   ABSTRACT
    This paper discusses  the  potential  impact  on utility operations of fugi-
tive  particulate matter  emissions  from  coal  storage  and handling.   It is
based primarily on a study completed by TRC for a large utility.

    Utilities  seeking  to convert to  coal firing or  preparing  to reactivate
older coal systems will be faced with a number of concerns, including:

      o  What are the probable magnitudes of the fugitive emission?

      o  What type of fugitive emission control systems are available?

      o  What modeling  techniques  are available to assess  the  impact on air
         quality of fugitive emissions?

      o  What are the  design  characteristics of various  types  of coal hand-
         ling components with respect to  fugitive emission potential?

      o  What  are  the ramifications  of fugitive emissions  control  with re-
         spect to BACT and LAER under the Clean Air Act?

In  developing  a fugitive  emissions  inventory and  applying the  findings to
decisions regarding the  feasibility  of  resuming  coal  firing, the utility and
TRC found it necessary  to formulate  answers  to the foregoing questions.  The
paper presents  discussions  related to  each  of these concerns,  with the ob-
jective  of  providing a  general  guideline to  the utility managers  who must
address these problems.
                                       81

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         1.0  FUGITIVE EMISSIONS CONCERNS FOR COAL STORAGE AND HANDLING
                         AT UTILITY GENERATING STATIONS

                                1.1   Introduction

     The U.S.  dependence on  imported oil  for utility  power generation  has
 continued to grow in the years since the  1973  oil  embargo.   Coupled with the
 Three Mile  Island  incident,  this  has  given major  impetus  to the  early  as-
 sessment of  opportunities  for  increased  power  generation  by  coal  combus-
 tion.   However,  the increased utilization of coal has been  cited  as carrying
 an inherently greater air  pollution potential than  any other form  of  power
 generation.   Among  the   potentially serious  sources of  air pollution  from
 coal-fired  power  generation  are  fugitive  emissions of  particulate matter
 from coal storage and handling operations.

     Utilities considering the switch to coal  firing,  or preparing to reacti-
 vate older  coal systems, must  be  concerned with fugitive emissions  from  the
 delivery,  loading/unloading, transport,  storage and  processing of  coal.   TRC
 has  recently  completed  a  study  for a  large  utility  which inventoried  the
 fugitive emissions  for  a  projected resumption  of   coal  firing  at  selected
 generating  stations.   The  major  technical  problem  of  the study  was  the
 meaningful   quantification  of  the  particulate  matter  fugitive   emissions.
 Direct  measurement  of such  emissions from individual  sources  is  an  exceed-
 ingly  expensive process, with  costs at  least  an  order  of magnitude  greater
 and  accuracy  inherently lower  than for  conventional  stack testing.  Thus
 estimation  of emissions  by emission inventory/emissions  factor  techniques
 although  not  nearly  as  well  defined   as  for  point source  emissions,  was
 selected.   Similarly, the nature  and performance of emissions  control  sys-
 tems  for coal  operations  fugitive  emissions  are not well  established,  and
 there is a  serious  lack  of  information  on the degree to which fugitive  emis-
 sions  can  be designed out  of the available  options  in  coal handling equip-
ment.

    Given this  framework,  a  stringent   schedule,  and a  limited  budget,  TRC
 sought  to predict fugitive  emissions quantities and  control  performance from
 information  available in  the  open   literature,  and  by the  application of
 judicious engineering judgment.   The calculated emissions  were   then  to be
used  as input to  a mathematical model  which would  predict  the  air quality
 impact  of the emissions  and  allow  individual  source contributions to be iso-
 lated.

    This paper reviews the  findings  of  the study, with  the objective of pro-
viding  general  guidelines  to  the   utility  managers  who  must address  coal
fugitive emissions  problems.  The  discussion will  be  directed to  the  fol-
lowing questions:


      o  What are the  probable magnitudes  of  the  particulate matter fugitive
         emissions  and how are they distributed  among  the  coal  system com-
         ponents?
                                      82

-------
o  What types  of  fugitive emissions control  systems  are available for
   each coal  system component, and  what are their  probable efficien-
   cies?  What is considered BACT?

o  What are  the  design characteristics  of various  types of coal hand-
   ling components  with  respect  to  fugitive emission  potential?   To
   what degree are these quantifiable?

o  What are  the  ramifications of coal handling  fugitive emissons con-
   trol, with respect to BACT and LAER under  the Clean Air Act?

o  What modeling  techniques  are available to assess  the impact on air
   quality  of particulate fugitive  emissions,  and  how well  can they
   isolate the contributions  of the  major sources  within the coal sys-
   tem complex?
                                83

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                              2.0   EMISSION FACTORS

     The answers to the  first  three  questions  raised in the Introduction were
 sought  through  a  comprehensive   literature  survey.   The  objective of  this
 survey  was  to determine  the range  of  fugitive particulate matter emission
 factors applicable  to coal  storage and  handling,  and the range  of  control
 efficiencies to be expected  from  appropriate  control  techniques.   The  liter-
 ature review  encompassed the recent studies by  PEDCO and Midwest Research
 Institute,  and  the  information generated  by  TRC's ongoing studies  for  EPA.
 In all  cases,  the  literature sources were  critically reviewed in  terms  of
 the means used to arrive  at  the  emissions factors given,  the  type of  opera-
 tion for  which  they were developed,  and their applicability  to existing  or
 visualized  coal  handling operations.   A  literature   pool  of   12  references
 resulted  from  this review,  and   formed  the basis  for the emission  factors
 used in the study.  These are given in the reference section of this paper.

     The fugitive  emission  factors   from  the literature  were   classified  as
 follows:


       o  coal  delivery:   rail car
                          barge

       o  coal  transfer:   belt conveyors
                          transfer  operations

       o  coal  storage:    active storage
                          inactive  storage


    Table  I summarizes  the  emission factors which  were  selected from the
 literature for these  classifications,  and also shows  further   refinement  of
 the  factors, based on a  critical  assessment of currently installed and ex-
 pected  equipment at the generating  stations  in question.  It is  this  step
which  requires  the application of engineering  judgment based  on experience
The "refined"  factors  which appear  in Table  I  therefore should be viewed  as
 somewhat site-specific,  and would  probably differ for other installations.

    In  applying  the refined  factors,  the use of  the  ranges is recommended
as opposed to so-called  "best estimate"  single values.   The  carrying  of  a
range  of calculated emissions throughout  the  process  will serve  to remind
all concerned  that the emission values  being  developed incorporate a consi-
derable  degree of uncertainty.

    The  form of  the emission factors  for  storage and  transfer   operations
raises  questions  as  to their physical validity.   For example,   the  literature
did  not  provide  a  specific  factor which  reflected   the  influence of  the
length of  a  conveyor, which  seems  the logical  way  of assessing  the emissions
from this  type  of source  (emissions  per  unit  length).   Thus the factors ex-
pressed  on the basis  of  through-put  of  coal  conveyed or  transferred  were
used, despite their obvious shortcoming in excluding the length  factor.

                                      84

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    In  the  case of inactive  storage,  one would  expect  the emissions  to be
related to  windspeed  and frequency  of  rainfall.   While  there  are empirical
emission  factor  equations  available which  take these into  account,  most of
the literature  emission factors were given in terms of  the quantity placed
in storage  (annual  basis)  and  this  convention was adopted  despite  the lack
of accounting for other physical aspects of the situation.

    In  the  case of  the active  stockpile,  it  is  recognized that  there  are
several   specific   emission-generating   processes  which   take  place;   i.e.
load-in,  load-out,  vehicular  traffic  around  the  storage pile,  and  wind
pickup.   Each process  would be expected to have  a specific emission factor.
Many  literature sources did,  in  fact,  attempt  to distinguish  among  these
individual  sources.   The typical  active  storage  operations are  usually lo-
cated relatively close  together,  and the  processes do not occur occur simul-
taneously.   Thus,   a  single  emission  factor  was  judged  to be most appro-
priate.   Fortunately,  such  a  factor  was  available in the  literature  (Ref. 4)
and  was  adopted  for  use   in  the  study.   The   single   value  given  (0.22
kg/metric ton)  was  assigned a  range of  0.11  to 0.33, in  recognition of the
likelihood  that,  even  if  obtained in  a  well-run experiment,  such  a factor
would be  determined from data  scatter exhibiting at least  a  +50% range.
                                      85

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                                                            TABLE  1
                             SUMMARY OF UNCONTROLLED PARTICULATE MATTER FUGITIVE EMISSION FACTORS
                                                FOR COAL OPERATIONS AT UTILITY
                                                         POWER PLANTS
             Operations
 Uncontrolled                 Refined Uncontrolled
Emission Factor (kg/metric          Emission
From Literature     ton)             Factorj
 Reliability
Ratings Found
In Literature2
00
Coal Delivery;

(1) Railcar

(2) Barge


Coal Storage;

(1) Inactive
    Storage Piles

(2) Active
    Storage Piles


Coal Transfer;

(1) Belt Conveyor

(2) Transfer
    Operations
                                             0.0001 - 0.2

                                             0.0001 - 0.2
                                              0.0553


                                              0.223
                                              0.02  -  0.5
                                              0.0755
                                   0.025 - 0.2

                                   0.01 - 0.1
                                   0.03 - 0.084


                                   o.n - 0.334
                                   0.02 - 0.2
                                   0.04 - 0.124
   B, C, D, E

   C, E
   B
   B
   D, E


   N/A (E)5

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                          3.0  EFFICIENCY OF  CONTROLS

    Information on  availability and  expected  effectiveness of  control  sys-
tems  for  fugitive   particulate  emissions   from  coal  operations  was  also
gleaned from the literature.  Again,  application  of engineering judgment led
to the refining of  the  literature  values  to  provide efficiencies which could
be applied to the existing  or  anticipated  installations under  study.   In the
case of  control  efficiency, a  single "refined" value  was  selected from the
literature range.   This  specificity could seem unwarranted  in  view of prior
discussion  regarding the  uncertainties  of  the  whole emission calculation
process.  However,  it was  felt  that  "engineering  judgment" is  more  consis-
tent with  a single  efficiency  value  than  a single-valued  emission  factor,
and  there  seemed to  be insufficient  justification for  further widening of
the range of uncertainty by assigning a control efficiency range.

    Table  2  summarizes  the control  efficiency values  which were selected
from  the literature  for the  same  coal  operation classifications used in
Table  1.  The  "refined" efficiency value is  given  along with  the  nature of
the  control  technique which  could be  expected to  provide  that efficiency.
The  "remarks"  column gives  information as  to  the  probable maximum  control
efficiency available  if cost  of control were  not  a  factor.   The  "refined"
efficiency value  and associated control  type   could  also be viewed  as   pro-
viding  a "practical" level  of  control,  at  least  as  far  as  the operations
which were the subject of the TRC study are concerned.
                                      87

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                                                                             TABLE 2
                                                                 SUMMARY OF CONTROL EFFICIENCIES
                                                            FOR PARTICOLATE MATTER FUGITIVE EMISSIONS
                                                           FOR COAL OPERATIONS AT UTILITY POWER PUNTS
                         Operations
                                                  Control
                                              Efficiency Range
                                              From Literature
                           Refined
                      Control Efficiency
                      & Nature of Control
                                                                 Remarks
                     Coal Delivery

                     (1)  Rail Car
                          Unloading
                     (2)  Barge
                          (a) Unloading
                          (b) Loading
90 - 99Z




70 - 90Z


50 - 90Z
95*
00
00
                     Coal  Storage

                     (1)   Inactive  Storage         50  -  100Z
                           Pilea
                      2)   Active Storage            50 - 75Z
                          Piles
Ventilation of
Enclosure to
Baghouse
75Z  Unventilated
     Enclosure

75Z  Telescopic
     Unloading Chute
     & Local Ventilation
     and Control
                       50Z  Wetting and Chenical
                           Stabilization
                       75Z  Wetting  & Chenical
                           Stabilization  Plus
                           Local  Ventilation
                           and  Baghouse
                               Complete Enclosure is Difficult
                               With Unit Train Dumping Systems
                          95Z Feasible With Enclosure,
                          Ventilation and Control, But
                          Very High CFM
                               Virtually  100Z  if Fully Enclosed,
                               But Not Usually Practical With  30,
                               60 or  90 Day Piles  at  Large
                               Stations

                               95Z Feasible With Enclosure,
                               Ventilation and Control, But Very
                               High CFM
                      Coal  Transfer
                      (1)   Belt  Conveyor
                      (2)  Transfer
                          Operations
 95  -  99Z
90 -  99Z
 97Z   Conveyors  Enclosed
      But  Not Ventilated
 98Z   Enclosed; Ventilated
      to Baghouse
                           99Z  If  Conveyors  Properly  Enclosed
                           & Ventilated  to Control, But Very
                           Sensitive  to  Leaks

                           Usually Enclosed  to Start With

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                 4.0   BEST  AVAILABLE  CONTROL TECHNOLOGY  (BACT)

    The requirements  of the Clean  Air Act Amendments  of 1977  specify that
new or modified  sources in certain  process  categories,  whose emissions could
impact criteria  pollutant  air  quality attainment  areas,  be required  to  in-
stall  Best  Available Control  Technology,  (BACT).  BACT  is  determined on  a
case by case  review basis,  and  only limited  information, as  shown  on Table
3,  is  presently  available  on BACT  for  coal  handling  fugitive  emissions.
Table  3  shows that  the required efficiency  of BACT  for coal  handling  and
storage and  similar  operations  could  conceivably range  from  an unspecified
"do  the  best you  can"  to  complete  enclosure with ventilation  and  baghouse
control and  99.7% efficiency.   The  control  efficiencies obtained  from  the
literature and "refined"  by TRC  as  shown on Table 2,  are generally consis-
tent with  the BACT values  given.   Only the  90%  efficiency of  the  raw coal
storage pile  dedusting  agent for the Region  V  Coal  Cleaning Plant seems  in-
consistent.   Lacking  more  detailed  information,  an  efficiency  of  50% would
be more  in keeping  with  the  information encountered  in  the  TRC  study.   At
best,  we  could visualize  no more than  75%  control  if  the  dedusting agent
were used  in conjunction  with carefully  placed windscreens/barriers  at  the
active sites  of  the  storage  piles.   90%  control is  expected to require  a
substantial degree of enclosure  or covering of  the pile,  in conjunction with
a dedusting agent.
                                      89

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                                                  TABLE 3
                        SUMMARY OF 8EST AVAILABLE CONTROL TECHHOLOGT DETERMINATIONS!

Process /Operation
Petrochemical
Coal Crusher
Coal Bunker
Coal Handling
FOR PARTICULATB MATTER
FOR COAL HANDLING AND

EPA BACT Strategy
Region Description
VI
Baghouse Filters
Baghouse Filters
Shrouded Conveyors;
FUGITIVE EMISSIONS
STORAGE OPERATION

Control
Efficiency
Specified
99.71
99.71

Remarks
Controlled efficiency
to include capture ven-
tilation system
(Totally inclosed)
                              Wa
                              Duie Collection  at
                              Transfer Paints
                                                            !Tot Given
 Coal Cleaning Plant

 Truck Sump


 Rotary breaker

 Raw Coal Transfer
      Jeltl

 •taw Coal Sampling
     Suilding

 Preparation Plant
    Duct Belt
                              Capture a Fabric Filter        SOX
                              Fabric Filter                  99*

                              Capture Plus Fabric Filter     30Z

                              Oaduscin; Agent                90Z


                              Dust Collector                 90S


                              Dust Collector                 991
 Coal Cleaning Plant

 Truck Dump

 Screen'i  Transfer
 Points

 Crusher

 Surge Sins

 Stock Piles

 Loading
                        17
                              Enclosed Wet Suppression       90Z

                              Enclosed 'Jot Suppression       90Z


                              Enclosed Vee Suppression       <>OZ

                              Not  Given                      90Z

                              Enclosed Wet Suppression       90X

                              'Jet  Suppression                 90Z
                                                  Assumed chat no  ventila-
                                                  cion used in conjunction
                                                  with these
Electrical
Generating  Station

Coal Handling
Spray Application
And Dust Collectors
                                                           Mot
                                                           Given
                                                                               Detailed  Control
                                                                               Stragaty  Info  is
                                                                               Given  Ln  Penait
Coal Classification
Plant	

Aggregate Coal
Storage

Loading Areas

•HI Shale Project

Roads, Parking Areas(
3rill Pads and Shale
Deposit Areas
                       VTII
                             Water Sprays
Water Sprays 6
Chemical Controls
                                                          Hot Given
                                                          "To Greetest
                                                           Extent Possible"
NOTES:

I.    SOURCE:  "Compilation of SACT/LAER De

                                            90

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                          5.0  MAGNITUDE OF  EMISSIONS

    The significance of  particulate  fugitive  emissions  may best be judged by
the  application of the  foregoing emission factors and control efficiencies
to a typical coal  handling  and  storage situation.   The calculations are sum-
marized on Table  4.   These are  abstracted  from the  TRC  study,  with appro-
priate simplification of  the system  and modification of throughput values.

    The "typical"  plant  is assumed  to burn 5000 metric tons  of  coal per 24
hours, which provides  approximately  5500  X  106  BTU/hr  heat input  and is
about equivalent to a 600 MW plant.

    The  total  fugitive   particulate  emissions  estimated  for  this   typical
plant  are  significant, even after  application of controls  which could  cer-
tainly be  considered  BACT.   At  the  high end of  the  range  of annual emis-
sions, over  100 TPY would  be  emitted.   The  active  stockpile  is  seen to be
the  largest  contributor  (40%  of the  total),  which is  not  suprising, since
this  operation  involves  actively  disturbing and  working  the coal  in the
open.  Significant additional  control could only be  achieved by completely
enclosing  the  operation,  and by  ventilating  to a baghouse  or other  control
device.  The maximum  contribution of  the conveyors  (30 metric tons,  or  21%)
seems  intuitively  too  high.  Although the  selected  upper value  for  the un-
controlled  emission factor  of  0.2  kg/metric ton is  well  supported by the
literature,  its application to each  conveyor  section may  be suspect.  The
available  information did  not  clearly  state whether the  conveyor uncon-
trolled factors  should be applied to  the entire conveyor  system, or  to  each
section.   In the  TRC  study, we adopted  the  latter,  more  conservative ap-
proach, and this is reflected in Table 4.
                                      91

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                                                                                TARLK 4
                                                             CALCINATION OF PARTICWUATE FUGITIVE EMISSIONS
                                                               FROM COAL HANDLING AND STORAttK OPFAATIONS
                                                               FDR A TYPICAL COAL FIRED GENERATING PIANT
10
                            Emission Source
                            An
-------
                        6.0  COAL HANDLING COMPONENTS

    The design  of  the  coal handling system components  can  significantly in-
fluence  the magnitude  of  uncontrolled  fugitive  emissions.   That is,  the
degree to which the design minimizes  the mechanical agitation of  the  coal,
will be  reflected  in reduced emissions.   The operations which are most in-
volved with such mechanical manipulation of  the coal,  and  which contribute
significantly to the total fugitive emissions  are:


      o  coal unloading
              from trains
              from barges

      o  coal loading
              to barges
              to trains

      o  active stockpiles
              coal delivery to the piles
              coal reclamation from the piles


    The  emission factor  literature  rarely distinguishes among various avail-
able equipment  arrays  for  accomplishing these functions.  Ideally, one would
assume that the uncontrolled emission  factor would range  from the high ex-
treme  to  the low extreme  as  the equipment's  inherent  capability to disturb
the coal  is decreased.  Unfortunately,  there is no  specific information to
support  this speculation  and  one  can  only  surmise in  a general  way  as to
which  method (e.g., of  delivering  coal  to  a storage  pile),  generates the
least fugitive  emissions.

    Figure  1  illustrates  this,  schematically  showing  two  ways  of  accom-
plishing  several  of  the  functions in the  order  of  (probably)  decreasing
emissions.

    For  barge  unloading,  the  continuous  unloader,  which is a  shrouded and
articulated  bucket conveyor,  would be  expected  to  generate  substantially
less fugitive  emissions  than the grapple bucket unloading  method.   The con-
tinuous  unloader  also  offers the  opportunity to apply reasonably  effective
local ventilation.

    In the  case of trains,  it  is  not  apparent that a  rotary car dumper de-
signed to  invert  coal  rail cars while they  remain  coupled, could generate
more fugitive  emissions  than a  single   car dumper,  except to the extent that
a  single  car is more readily enclosed.   The  unit  train system would operate
more rapidly and  thereby  generate more  emissions   in  a given  time period,
given equal  control effectiveness.   In either case, the train unloading sys-
tem can  be  expected to  be enclosed, ventilated  and controlled,  so in this
case,  the  degree to which one  version can generate more fugitive  emissions
than the other may be a moot point.

                                     93

-------
    Active stockpile  coal  delivery is shown  in  two  versions.   One entails a
free  drop to  the  stockpile,  while  the  second incorporates  a  telescoping
chute  to essentially  enclose  the  coal  stream  during  the  drop.  it  is ap~
parent that the latter method will  generate less fugitive emissions.

    Coal  pile  reclamation is shown in two systems  which  could be construed
as "manual" vs.  "automatic".  The  use of earth moving  equipment  around the
pile,  such as  bucketloaders, bulldozers  or  graders  which carry or  push the
coal  to  underground  hopper/conveyor  systems,  can  be  expected to  generate
substantially  greater fugitive  emissions  than  an  articulated  bucket  wheel
stacker/reclaimer with  associated  conveyors.  The  latter would be  shrouded
and can be subjected to local ventilation and control.

    In summary,  the design  features  of  coal handling  component and systems
can be  a positive  factor  in minimizing  fugitive  emissions  from  the  operar-
tion.  Quantification of  emission  characteristics  for  various  designs  is
beyond the present  state  of knowledge,  and  only  educated estimates  can  be
used to recognize that  one component  array may  generate  less  emissions than
another.
                                     94

-------
                     FIGURE  1:    THE  EFFECT  OF  COAL  HANDLING
                          COMPONENTS  ON  FUGITIVE  EMISSIONS
  UHLOftSING.BARGES
              GRAPPLE
              BUCKET   '
            „,.     CONTINUOUS
          'OPPE1<       BASGE
        •CONVEYORS    UNLOAOtR
                    ;BUCKET
                   COKVEVORj
                                          UNLOAD 116
                                         "~ TOWER
                                                      ',E.'_:JHT;NUOUS
                      CNCLCSURE
          UN3EP
           HOW'S
              L*i JK1T
                                                             (8) S1KCLL CAR OUHPfR
ACT.L CTOCy.'I^'.
 C0nu JEUVERV
   'OWES
                             	ENCLOSED
                             iOOH COKVEYOP
    RECLtHtTION FROM PILES
       ACTIVE
        PILE
  tUCkET LOADER
—0!! OThtP. C3AL
 MOVIN& MACHINERY
           (S)-CQ
                  RECLM1ATIOH F?0>< ACTIVE
                  STOCl.PiLE Br COAL MOVISu
                                                          CHUTE EHCLOSED DW  TO STQQ.PlLi
_ 6UCSET WHEEL
STACKER-HECL^MEP
            /
                                                         (0; RECLAHAT1W* FROM ACTIVE
                                                            STOCf.rlLE BY SUO.n il^ii.i

-------
             7.0  MODELING OF FUGITIVE PARTICULATE MATTER EMISSIONS

     The foregoing  sections  nave described  concerns  and methodology  related
 to the quantificaton of  fugitive particulate matter  emissions,  and  the  means
 available for their control.  Determination of  the  impact  of  these  emissions
 on ambient air quality and  their specific  contribution  to  ambient concentra-
 tions  requires  the use  of  sophisticated  mathematical  modeling  techniques.
 These techniques also  are needed to  assess  tradeoffs in  the  application  of
 controls  to  individual  fugitive  emissions  sources,   and to  nearby  point
 sources.

     The  immediate  need  for  such  refined analytical  techniques  has   been
 acknowledged and met by  EPA with  the recent development of advanced  disper-
 sion models.   The Industrial Source Complex (ISC) Dispersion Model  developed
 by the H.E.  Cramer  Co.  Inc., and the CDMDEP Model, a modified  version of  the
 Climatological  Dispersion Model (COM), developed by TRC Environmenal Consul-
 tants are two such  models prepared  for the  EPA.

     The ISC  Dispersion Model  combines  and enhances  various  EPA dispersion
 model algorithms into  a  set of  two computer  programs  that can  be used  to
 assess  the air  quality impact  of emissions from a  wide variety of sources
 associated with  an industrial  source  complex such  as a  Power Generating
 Station.

     The ISC and  CDMDEP models  have been designed  to account   for mechanisms
 which influence  the dispersion  and  quantification  of  particulate plumes
 These mechanisms  include:


      o  dry  deposition

      o   gravitational  settling

      o  washout

      o  building wake  effects

      o  vertical wind  profile variations

      o  plume rise


Stack,  Area  and Volume sources  can  be simulated by  the  ISC Model  programs.
Long-term  concentrations  of total  suspended particulate matter due  to emis-
sions from point  and area sources can be estimated by CDMDEP.

    Short  term  or  long-term  source-receptor  relationships  can be  derived
using the  ISC Dispersion Model.   The  ISC  Short Term Model (ISCST) is  de-
signed to  calculate  concentrations  or deposition values for time  periods of
1, 2,  3,  4,  6,  8,  12  and  24 hours.  The  ISC  Long  Term Model  (ISCLT)  uses
STAR  Meteorological Summaries  to calculate  seasonal and/or   annual  ground
level concentrations or deposition values.

                                     96

-------
    The input  data required  to  run either  ISC or  CDMDEP  consists of  four
categories:


      o  Meteorological Data
      o  Source Data

      o  Receptor Data

      o  Program Control Parameters


The details  of  the input data are  given  in references 13 &  14.   The  output
from  these mathematical  models  provides  a  quantitative  estimate  of  the
spatial  distribution  of  air quality,  averaged over  the  time period  con-
sidered.  Contributions from major  sources  within  the  industrial  complex can
be identified and  appropriate  controls prescribed.  It should  be  noted that
these  advanced,  complicated models are intended to be  used  by Air  Quality
Engineers  and/or Meteorologists  familiar  with  effluent dispersion  charac-
teristics  and  computer  techniques.   The  models,   with  proper  fundamental
knowledge, can be applied to other types of studies such as:


      o  Stack design

      o  PSD analyses

      o  Source Permit Applications

      o  Monitoring Network Design

      o  Regulatory Variance Evaluation

      o  Control Strategy Evaluations

      o  Fuel Conversion Studies

      o  New Source Reviews

      o  Analyses of Emission Offsets
                                      97

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                               8.0  CONCLUSIONS

    This  paper  has reviewed a methodology  for  estimating the quantities and
degree  of control  for fugitive particulate matter  emissions  from coal hand-
ling  operations.   Available information in the  form of emission factors and
estimates  of  control efficiencies was  found  to be  relatively sparse and to
vary widely.  Information  on BACT controls  is also limited at present.  Con-
siderable  judgment must be  incorporated in  the  application  of information.
The  estimation  of  well-controlled  fugitive  particulate  emissions   from  a
typical  coal-fired plant  results  in  significant residual emissions, of which
a  large  proportion is due to  actively  working  the stored  coal  in the open.
More  information  on the relationship between coal  handling equipment design
characteristics and  fugitive emissions  is needed.

    Mathematical Models  are available  which  will  discriminate among various
fugitive  emission sources  and elevated point  sources  to  isolate  their in-
dividual  impacts  on ambient concentrations of  suspended particulate matter.
Application of  these models completes  the  assessment  of  fugitive emissions
and leads  to the formulation of cost-effective control  strategies.

    There  is  at  present   enough  information  to  only  generally  guide those
managers  who  must  address  coal   fugitive emission  problems  at  utility  sta-
tions.   Each  site will  have  its  specific  problems  and  constraints.   The
manager  is urged  to approach .the  problems  utilizing  a  broad  team  of  ex-
perts.  Air pollution control  engineers, power  generation specialists,  dif-
fusion  meteorologists,  coal   systems  designers, environmental  consultants,
and environmental  attorneys  can  all provide  important  inputs to the problem
solutions.  The success and  cost effectiveness  of  the  solutions  will depend
on how well the efforts of the team are orchestrated.
                                     98

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                               9.0  REFERENCES

    The following references are pertinent  to  the  quantification  and  control
and modeling of fugitive particulate matter emissions from  coal handling  and
storage operations.


1.  U.S.  Environmental  Protection Agency.    Compilation  of  Air  Pollutant
    Emission  Factors.    3rd.  ed.,   Including   Supplements  1-7.   U.S.  EPA.,
    Research Triangle  Park,  NC.   August 1977.   AP.-42.  pp.  11.  105;  11.2-1
    to 11.2-5; 11.2.3-1 to 11.2.3-2.

2.  Currier,  Edwin  L.,   and   Neal,   Barry  D.,  "Fugitive   Emission  from
    Coal-Fired  Power  Plants",  paper  79   -   11.4,   Air  Pollution  Control
    Association, 72nd Annual Meeting, Cincinnati,  OH., June  24-29,  1979.  pp.
    15.

3.  Jutze, George A.;  Zoller,  John M;  Janszen,  Thomas A.;  Amick,  Robert  S.;
    Zimmer,  Charles  E.;  and  Gerstle,  Richard  W.   Technical Guidance  for
    Control  of  Industrial  Process Fugitive  Particulate Emissions.   PEDCO.
    Environmental,  Inc., Cincinnati, OH.March  1977.EPA-450/3-77-010.  pp.
    2-5 to 2-43.

4.  Cowherd,  Chatten,   Jr.,  et  al.   Development   of Emission  Factors  for
    Fugitive  Dust  Sources.  Midwest  Research Institute,  Kansas  City,  MO.
    June 1974.  EPA-450/3-74-037.

5.  Blackwood,  T.R.  and Wachter,  R.A.   Source  Assessment!   Coal  Storage
    Piles.   Monsanto  Research Corporation, Dayton,   OH.   Sponsored  by  U.S.
    EPA, Cincinnati,  OH.  EPA-600/2-78-004k.  May 1978.  83  p.

6.  Bohn, Russel; Cuscino,  Thomas  Jr.;  and Cowherd,  Chatten Jr.   Fugitive
    Emissions  from  Integrated  Iron  and   Steel  Plants.    Midwest  Reseach
    Institute, Kansas  City,  MO.   Sponsored  by  U.S.  EPA,  Research  Triangle
    Park, NC.  March  1978.   EPA -600/2-78-050.  p. 262.

7.  Axetell, Kenneth  Jr.  Survey  of  Fugitive Dust  from Coal Mines.   PEDCO
    Environmental,  Inc., Cincinnati, OH. February  1978.   EPA-908/1-78-003.

8.  Ambrose, D.; Brown, D.  and  Clark,  R.,  "Fugitive Monitoring  at   a  Coal
    Clenaing  Plant   Site."   In  Second Symposium  on  Fugitive   Emissions;
    Measurement and  Control.  May 1977,  Houston,  TX.   TRC  - The  Research
    Corporation  of    New   England,   Wethersfield,   CT.    December   1977.
    EPA-600/7-77148.  p. 64-113.

9.  Boscak,  V., and Tandon,  J.S.   "Development of  Chemical(s)  for Supression
    of  Coal Dust Dispersion from  Storage  Piles."   Paper  presented  at  4th
    Annual  Environmental Engineering and  Science  Conference, University of
    Louisville, Louisville, KY.  March 4-5, 1974. p.  14.
                                      99

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10. Amick,  Robert  S.  and  Wisbith,  Anthony  S.   Fugitive  Dust  Emission
    Inventory  Wasatch Front,  Utah.   PEDCO-Environmenta 1  Specialists,  Inc/"~
    Cincinnati,   OH.   Sponsored  by  U.S.   EPA,   Denver,  CO.   July  1975.
    EPA-908/1-76-001. p. 20.

11. Cross,  Frank L.,  Jr.,   and Forehand,   Gerald  David,   editors.    Air
    Pollution  Emissions   from  Bulk  Loading  Facilities.    (EnvironmentaT
    Monograph  Series,  V.6.)  Technomic  Publishing Co.,  Inc.,  Westport   GT
    1975. p. 22

12. Zoller, John M.; Wood, Gilbert H.;  Jansen,  Thomas  A.,  "Current Status of
    Process Fugitive Particulate Emission Estimating  techniques.:   In Second
    Symposium  on Fugitive  Emission;    Measurement  and Control.   May  19777"
    Houston,   TX.    TRC  -   The   Research  Corporation   of  New  England*
    Wethersfield, CT.  December 1977.   EJPA-600/7-77-148.  p.  385-456.        *

13. Bowers,  J.F.; Bjorklund,   J.R.;  and  Cheney,  C.S.   Industrial  Source
    Complex (ISC) Dispersion Model Users Guide, Volume  1.  EPA,  Contract  Nb7
    68-02-2507, H.E,  Cramer Co. Inc.,  April  1980.

14. Bowne,  N.E.;  Wackter  D.J.;  Lazorick,  S.W.   TRC;  Final Report   to EPA
    CDMDEP  -  A  Climatological Dispersion  Model  for  Sources  of  Suspended
    Particulate Matter!  EPA, Contract No. 68-02-2615,  Task No.  4, September"
                                    100

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           Design, Performance Testing and Field Operation  of
           an Isokinetic Electrostatic Particle Sampler

                                Bengt Steen
           Swedish Water and Air Pollution Research  Institute,
           P.O.  Box 5207, S-402 24 Gothenburg,  Sweden.
Abstract
An isokinetic electrostatic particle sampler is described.  Its  perfor-
mance is investigated both in laboratory and field operation.

The sample flow is generated from the inertia of the surrounding air
flow. The particles in the sample flow are deposited inside a  cylindrical
collector electrode, which is weighed before and after the  sampling period.
Afterwards, the sample can be further analyzed for its chemical composi-
tion or physical properties.  The particle flux is obtained by dividing
the inlet nozzle area with the sample mass and the sampling time.

The collection efficiency has been studied under various controlled con-
ditions. It is seldom lower than 90%, but often above 97%.  Wind tunnel
tests have been performed to study the deviation from isokinetic sampling.
The maximum deviation found was 8% in the 0.5 - 26 m/s range.

The sampler may be used for measurement of fugitive dust emission, its
operation being wind-directed and the sampling being merely in a 45-
degree-sector or similar. Evaluation procedures for fugitive emissions from
ideal point sources, line sources and surface sources are presented.

Experiences from field measurements are reported. Measurements have been
performed in roof ventilators and around an open stock pile area of a
smelter industry. In the latter case 13 samplers placed in  4 masts were
operated during one year.
                                    101

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             Design, Performance Testing and Field Operation of
             an Isokinetic Electrostatic Particle Sampler.

             Bengt Steen, Swedish Water and Air Pollution Research  Institute


 General

 Measurement of fugitive dust emissions are more difficult  to perform  than
 other dust emission measurements.  Several  factors complicate the measure-
 ment:
             - particle sizes are often large

             - changes in both flow velocity and direction  may occur

             - part of the emission may be  occational,  for  instance
               in connection  with high  wind speed.   This  requires
               long sampling  periods to obtain  necessary  statistics

             - the extension  of areas with  high fugitive  emission
               source strength is often vaguely known

             - areas with fugitive  emission are often large,  which
               calls for many measurement points

 Taking  these  complicating factors  into account emphasis  should be laid upon
 two  qualities of a good measurement method for fugitive  dust emissions*

             - isokinetic sampling

            - low cost

 Five years ago we developed  a  sampler  at our institute to meet these
 quality demands  (1).

 Design

 After some field  experience  the  sampler was modified. The new design is
 shown in Figures  1  and  2.
 The sampler consists basically of a nozzle, a  cylindrical collecting elec-
 trode, an emission  electrode, a  flow regulator, a shaft and a high voltage
 generator.

 During sampling,  the axis of the cylinder  is parallel with the flow lines
and the fluid is  allowed to  pass isokinetically through the nozzle by means
of its own inertia. The particles are charged and collected on the inner
cylinder wall by  electrostatic forces.  The cylinder is  weighed before and
after the sampling  to determine the particle mass. The  particles may also
be analysed by chemical or physical means.
                                    102

-------
 The  particle  flux  is determined by dividing the sample mass with the nozzle
 area and  sampling  time.

 The  nozzle  diameter is such that approximately 25 times reduction of the
 air  velocity  is obtained inside the sampler. The combined dimensions of
 the  nozzle, the collecting electrode, the outlet holes and the venturi
 screen  result in an isokinetic flow through the nozzle tip.

 Performance tes ti ng

 Measurements  of the flow velocity in the nozzle and in the main gas stream
 showed  little or no difference from isokinetic conditions, (table 1).
 The  deviations are such that to some degree they compensate a decreasing
 sampling  efficiency at high wind speed.


   Flow velocity              Flow velocity
   in main gas stream         in nozzle tip of              Note
                               the sampler
        (m/s)	(m/s)
0.5
0.8
2.3
3.4
5.5
9.8
12.3
25.8
0.5
0.8
2.3
3.4
5.6
10.0
13.0
28.0
measurements made by hot
wire anemometer at room
temperature
_«_
-»-
„"-
_u_
measurements made with
                                         static and dynamic pressure sensors
                                                 at 260 °C.
Table 1    Results of flow velocity measurements in nozzle tip and
           in main gas stream

The collection efficiency of the sampler has been tested at various con-
ditions. The influence of particle size, concentration, flow velocity,
amount of collected material, particle material, and battery current
has been studied (1).

The experimental set-up consisted either of:  (a) the sampler, a filter,
a dry gas meter and a pump; or  (b) the sampler, a Royco 220 light scatter-
ing particle counter and a pump.

Table 2 shows the results obtained by using a Royco particle counter when
determining the concentration of different particle size classes present
                                      103

-------
in a room atmosphere before and after the sampler.  The sampler was  used
without a nozzle and with a flow velocity of 1 m/s  inside the collection
electrode. The particle number concentrations were  low, around 1000/1  in
the 0.3-0.4 \im range and 10-21/1 in the 3.4-6.6 ym  range.
   Latex equivalent
   particle diameter
    Sampling efficiency (%)
      Battery current (mA)
6       8       10       50
                                                                196







Table

Table

0.3-0.4 73.7 83.2 93.7 97.6
0.4-0.6 72.9 83.8 94.5 97.5
0.6-1.0 75.6 86.1 96.0 98.0
1.0-1.8 77.6 92.2 96.3 99.3
1.8-3.4 78.7 92.4 99.7 100
3.4-6.6 78.2 92.9 98.7 100
6.6-13 88.3 (80.0) 100 100
2 Collection efficiency of sampler for different parti
size classes at different battery currents
3 Collection efficiency obtained from measurements of
types of particles.
99.0
98.7
99.2
100
100
100
100
cle

different

Gas velocity
at nozzle
(m/s)
0.8






0.8


13.6


0.8
0.8

0.8


Nozzle Battery Type of Amount of Collection
d1a. current particles collected efficiency
(Tim) (mA) | dust (mg) %
25 50 I Redispersed 27.8 99
1 soot from
oil combustion
25 50 | Redispersed 8.7 98
Na^SO. from
kraft pulp mill
recovery furnace
25 50 Talc powder(mass 23.6 98
mean aerodynamic
diameter « 2. 5 urn)
5 -x.150 Emissions from 389 97.5
electric arc
steel furnace
25 50 | Fe2 03 8.4 100
25 50 Particles in 5.3 91
ambient air
25 50 Sulphate in 0.201 87
particles in
ambient air
                                    104

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The collection efficiency obtained by the filter method for various types
of particles are shown in Table 3.

Comparative measurements between two samplers at different angles were
made in a wind tunnel. The purpose was to study the influence of deviations
between the direction of the main flow and sample flow on sample flow velo-
city.

Talc powder with a mass mean aerodynamic diameter of 2.5 ym was used at a
wind velocity of 4 m/s. The result is shown in Figure 3.


Selection of sample points and data evaluation

Since the position and extension of a fugitive dust source generally are
not known, many measuring points in an envelope surface around the source
are needed to determine the total emission. By using an infinite amount of
measuring points the location and evaluation are fairly easy to make.
However, economic realities will put a limit to the number of measuring
points. Presumptions or knowledge of the position and character of a certain
source usually enable adequate measurements of the emission even by using
a few samplers. A few such cases will be discussed below.

In all cases it has been assumed that the background is zero and that nothing
of the emitted dust has been deposited between the emission point and the
sampler.
An ideal point source  emits dust from one single well-defined point.
Welding, loading- and unloading operations, minor storing places and open
fires usually could be treated as ideal point sources. The size of the
emission from an ideal point source is here supposed to be independent of
the wind direction.

If one puts an imaginary cylinder with vertical axis and with the bottom
surface concentrically with the source the particle flow through the enve-
lope surface of the cylinder will be identically with the emission, provided
that the cylinder wall is high enough and that the background is low.
The particle flow through the envelope surface could be determined by using
samplers located at different heights in the cylinder wall. If one mast
with n samplers is used the emission will be the following

                             mi • 8 rh

                             n •  dz • f
                                     105

-------
 where
 m. =  quantity of  sample in the ith filter

 n  =  number of samplers

 r  =  radius of cylinder
 h  =  height of cylinder

 d  =  dia. of the sampler nozzle

 f  =  relative frequency of wind direction in the  sampling  sector
       (Frequency of wind direction in the sector divided with  the
        frequency in the sector if the wind was blowing with equal
        frequency from all  directions)

 If the background is high  the particle flow coming in through  the opposite
 side of the cylinder has to be measured and subtracted from the flow of
 the leeward side of the source.
 An  ideal  line  source  is  here  defined as a source which form looks like a
 line  and  which emission pro length  unit is the same along the whole line.
 A road, a ditch  or  belt  conveyor usually could be regarded as an ideal
 line  source.

 If we  look at  a  length increment,  dL at the line source as a point source,
 the following  is valid
                     Zmi,L
8-h-r
	  =  dL- a
                       n-d2 • f

where
a  =  the emission per length unit, and ID. ,   is that part of the sample

which emanates from the length unit dL. If we integrate over the whole
length of the line source (L«) in the measuring sector we get:


             ' 8>h                 C-Q    HI
       	'	  =   a .       I  u   _dk_          	  (i)
          n • d  •  f             L=0)       r

This integral will here be solved for the case that the line source is
a straight line which crosses  both sides of the sampling sector (see fig.  4).
                                     106

-------
The equation of this straight  line  equation expressed in polar coordinates
is:
                     r  =   cosa -  k  sina	   where k and p are constants.
Further      L = -v/(p - r-cosa)2   +   r2sin2a
                                    _)2  , P^  ' sin2a           «
                                     /    />****».»   If   & ^ _ . i ~
                           .     .
                    cosa -  k  •  sina        (cosa - k  • sina )
          /k2 •  sin2a + sin2a    =    p  . sina       .   f~\
         ^    (cosa - k •  sina)2   ~    cosa  -sina      V k  +
       dL _  _.,A.2    ,    sina • (sina + k •  cosa )  + (cosa - k-sina) • cos a
       -r- -  fjy K.   1-  I • - -< - - - - ' -
                                         (cosa - k • sina ) *


       =  pjk2  +  I
           v
                         (cosa -  k •  sina )

(1) then would be expressed as:

                            a,
          ,-  8 •  h          (     /2
                    =   a-    I p-yk  + 1 -(cosa - k • sing)  da  =
I
       n •  d  •  f          JL   (cosa  - k  • sina ) * • p
                                                              a
                                                  / I,i\/l^i1 J.4-,
                                           = a-ln
If a is released we get:

             £m.  •  8 •  h      /     (k + ^/k2 + l +tg|) (k -y/k2 + 1 ) "

               n -  d2 •  f      I    "  (k-./k2 + l +tg|) (k+Jkz + 1 )
Suppose that the extension of the  surface  source  is  limited by four lines
which in polar coordinates are  the  equations  r = r,  r = r2,a = 0 and
a = a, (a is given in radians).  The  measuring  point  'is placed in origo.
In thi same way as earlier we will get  the flow through a vertical slit
in origo:
                                     107

-------
          '-'  4            '•    '-    r  • da  • dr  • e • f
       n  • IT  • d          1     |     2-ir.r-h
e = the emission per surface unit.
                                          m.  - 8  • h
Then we will get:                  e =  	~~
                                         f  • n  • d   • a1(r2 - r, )


Field experience

The field experience with the sampler includes measurements in roof venti-
lators and a one-year measurement of the emission from a stock yard of a
smelter industry in northern Sweden.
An example of the location of samplers in a roof ventilator is shown in
Figure 5.

Figure 6 shows a particle sample collected in a roof ventilator above an
electric arc steel furnace. The particles were collected on an aluminum
foil.

With a conventional technique including flow measurements and isokinetic
sampling the same measurements would require several times the man power
and equipment investments.
 £2£lLy§rd_measurement
Fugitive emissions from a stockyard were measured using 13 samplers during
one year.

The samplers were mounted at light masts in the area as shown in Figure 7.
They were directed towards different fugitive dust sources (Figure 8).
The sampling took place with the wind blowing from these sources against
the sampler and in a sector of  - 22.5 degrees from the main direction.
One month samples were taken. The particles which had isokinetically passed
through the sampler nozzle were collected on an aluminum foil, which weight
was determined before and after the sampling period. The aluminum foil then
was rinsed in distilled water and the suspension was analysed for Cu, Pb,
Zn, As and mercury by means of ASV and atomic absorption spectrometry.
                                     108

-------
The fugitive emission was  calculated in  three  ways.  The results differ
only slightly and  is shown in Table 4. The losses of Cu and  As is approx-
imately 1  - 2 % of the handled  amount of material.
Table  4      Total  amount  fugitive  emission calculated  in three  ways
                                          I Estimated total emission ton/year
                                                                             1 0 13 I
        Calculation criteria                | Cu      Pb      Zn     As     Hg    Dust


        Total emissions  from single         ,
        point sources.                      I 15      7.5     140    1.7    0.23   2800

        Total fugitive dust transportation
        from material handling yards,  cal-   '
        culated from the transportation      |
        above the south  bank (the poles  A
        and B) which was multiplied with    I
        3.7 (the area is presumed surrounded j
        by a square. Through one of this
        sides the flow was measured)        I  6.9   (25)x    110    1.4    0.055  2200

        Mean dust flow in the area without   '
        consideration of the location  of    |
        the samplers multiplied with the
        envelope surface of a cylinder with  '
        a  radius of 400  m and a height of    [
        25m (will surround the area)        , 14     (35)     220    2.5    0.18   2200
             the lead storage yard at the
              A-pole  disrupt the result
                                          109

-------
References
(1)   B.  Steen,  "A new  simple  isokinetic sampler for the determination of
     particle  flux". Atmospheric Environment, Vol 11, pp. 623-627 (1977).
                                  no

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                                   Emission electrode
                                              Nozzle
                                Isolating support
                                           Water proof
                                           box
FIGURE  1    Isokinetic electrostatic particle sampler
            Principal sketch
                            111

-------
1) Housing  for high
   voltage  generator
2) Shaft with high
   voltage  wire
3) Connection  with
    teflon plug
4)  Flow regulator
5)  Ball bearings
6)  Collecting electrode
                                 ^   m.
                                 ©   il
 7) Relay
 8) Magnet  for  7)
 9} Nozzle
10,11) Two position nozzle  valv«
12) Magnet
13) Adjustment screw
14) Vanes
        FIGURE  2    Wind-directed  measurements
                              112

-------
           Sampling   efficiency (weight %)
                                                Flow
                                           06   direction
                                                Angular
                                                deviation
                                                (00°)
         0  10  20  30  40  50  60  70  80 9O
FIGURE 3   Percentage of main flux of talc dust obtained in a
           sampler oriented angular to the main flow direction
           at 4 m/s wind velocity
                              113

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Line source
   FIGURE 4    Line source
              114

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FIGURE 5   Measurement of fugitive emissions from roof
           ventilators.  Location of samplers.
                           115

-------
FIGURE 6     Unfolded foils with dust collected  in  a  roof
             ventilator above an electric arc  furnace.
                           116

-------
          Cu- material
          unload :2.5 kton/yr
     material
     unload:
     12-14
     kton/yr
                            material
                            unload:
                            8-10 kton/yr
                                            Pb-
                                            aterial
                                          unload:10:12 kton/yr
                                          load /^10 12
FIGURE  7    Simplified overview of raw material handling
            and measurement sectors
                              117

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FIGURE 8       Samplers mounted on masts.
                          118

-------
                  ASSESSING HAZARDOUS  WASTE  TREATMENT  FACILITY

                           FUGITIVE  ATMOSPHERIC  EMISSIONS


                                      By

                                Tim S. Sekulic
                                      and
                                 B.T.  Delaney

                         Fred C. Hart Associates, Inc.
                              New York, New York

                                   ABSTRACT


     A program of sampling and analysis for the identification and quantifi-
cation of atmospheric emissions and the development of emission factors for
all aqueous waste storage, treatment,  and disposal  processes at a hazardous
waste management facility has been developed.   Samples for atmospheric
emission characterization will be obtained via at least two complementary
methodologies, wherever possible, as follows.   At the facility's aqueous
waste receiving and physical/chemical  treatment lagoons, composite liquid
samples will be obtained for equilibrium vapor analyses, and in situ surface
sampling, using an enclosure technique, will be performed.  At the aerated
biological oxidation ponds, these methods will be supplemented by an emis-
sion profiling method.

     The organic vapor content of all  air samples will be analyzed with a
Century Systems Organic Vapor Analyzer (OVA) with a self-contained gas
chromatographic/flame ionization detector system.  Initally, OVA analyses
will be duplicated using a laboratory gas chromatograph/mass spectrometer
for verification and calibration of results.  Additionally, impinger absorp-
tion samples will be collected for the determination of ammonia, amine, and
acidic vapor emission rates.

     Measured pond and lagoon emission rates will be used to develop emis-
sion factors (mass emission rate per unit of surface area), and mass trans-
fer coefficients will be determined for a theoretical emission rate ex-
pression which has been developed.   Further, sampling results will be used
to identify potentially troublesome (e.g., toxic or odorous) emissions from
any process.  A meteorological monitoring station is also being installed
for correlation of meteorological conditions to sampling results and for
future analysis and prediction of atmospheric emission problems.

     Sampling results are not yet available for discussion; therefore,
concentration is given to the details of the planned sampling and analytical
program and the computation methodology, for characterizing the facility's
waste treatment pond and lagoon emissions.
                                      119

-------
                                 INTRODUCTION
      Hazardous waste management facilities  may contain  significant  sources
 of both  stack or point  and fugitive  atmospheric emissions,  depending  upon
 the nature  of the waste materials  and  the particular  processes  and  opera-
 tions employed.   Methods for measuring point  or stack emission  rates  are
 well  defined,  and emissions of  many  point sources  have  been fairly  exten-
 sively quantified.   Fugitive emissions,  however, have received  much less
 attention and have not  been well quantified.

      The sampling and analysis  program described here has been  developed for
 the identification and  quantification  of fugitive  atmospheric emissions from
 aqueous  hazardous waste treatment  processes.   The  results of this program
 will  be  used  to develop emission factors and  mass  transfer  coefficients for
 use in a theoretical  emission rate expression which has been developed, and
 to identify potentially troublesome  (e.g.,  toxic or odorous) emissions.
 Although a  comprehensive program for emission characterization  involving all
 of the treatment,  storage,  and  disposal  operations of hazardous waste treat-
 ment  facilities has been developed,  the  discussion here concentrates pri-
 marily on the  aqueous waste ponds  and  lagoons.  Sampling results are not yet
 available,  so  this  discussion is limited to the details of  the  planned
 sampling and  analytical  program and  the  emission rate computation metho-
 dology.
                                 BACKGROUND
               Hazardous Waste Management Facility -- Aqueous
                     Waste Treatment Processes/Emissions
     The facility for which this atmospheric emission characterization
program has been developed is a relatively advanced, comprehensive pro-
cessing, recovery, and disposal plant for a wide range of liquid and solid
hazardous wastes.  The capabilities of this facility include the bulk trans-
fer of wastes; solvent and fuels recovery; physical, chemical, and biologi-
cal treatment of aqueous wastes; and secured scientific landfill of solid
material.   Since the emphasis of this paper is the characterization of
atmospheric emissions from the facility's aqueous waste ponds and lagoons,
the aqueous waste treatment system will be reviewed here.

     The aqueous waste treatment system consists of four unit operations:
(1) chemical oxidation and reduction; (2) neutralization and precipitation;
(3) carbon adsorption; and (4) biological treatment (Figure 1).   Incoming
aqueous wastes are sent to the oxidation-reduction system, consisting of
                                    120

-------
                                   FIGURE 1
                                                           SLUDGE TO
                                                        -^•SCIENTIFIC LANDFILL (SLF)
HOLDING
LAGOON
 REDOX
SYSTEM
     ACID
NEUTRALIZATION
   SYSTEM
      AIR
                   . COLD WEATHER ONLY
        FACULTATIVE
            POND
       (COLD WEATHER)
                       ±
                                                       pH ADJUSTMENT
                                                           TANK
                 HIGH RATE
                BIOAEROBIC
                TREATMENT
                              CARBON
                            ADSORPTION
                             SYSTEM
   AIR
                            *. DISCHARGE
        FACULTATIVE
            POND
           SYSTEM
                                              AQUEOUS   WASTE
                                            TREATMENT  SYSTEM

-------
 three lagoons in series, in which the wastes are chemically oxidized and
 reduced.  Wastes containing reducing agents are sent to one lagoon; wastes
 high in organic matter or containing oxidizing agents are sent to a second
 lagoon; and wastes from these two are mixed together into a third lagoon,
 which is always maintained in a slightly reducing state to promote heavy
 metal precipitation.

      Following oxidation-reduction,  the waste enters the neutralization-
 precipitation system.   Here the pH of the waste is increased to approxi-
 mately 11.5 by the addition of lime in an agitated vessel.   The resulting
 alkaline slurry is then conducted to a gravity separation area, the salts
 lagoons, where the heavy metals settle out as metal  hydroxides.

      The supernatant from the salts  lagoons is transferred to a holding
 pond, after which its  pH is adjusted to approximately neutral,  and it is
 sent through sand filters prior to treatment in the  carbon adsorption sys-
 tem.   In the carbon adsorption system,  the organic content of the waste,
 particularly the high  molecular weight organics,  is  reduced substantially.

      Following carbon  adsorption,  the waste enters the biological  treatment
 system.   The first stage of biological  treatment  is  a high  rate aeration
 system consisting of a 500,000 gallon tank with a  40 horsepower surface
 aerator.   This is followed  by the  facultative pond system,  consisting of a
 series of large, aerated ponds,  where biological  reduction  of the waste's
 organic  matter continues.   The final  step is the  storage of the treated
 wastewater in aerated  ponds prior  to  discharge  into  natural  water bodies.

      The many open ponds and lagoons  of  this aqueous  waste  treatment  system
 expose large surface areas  from  which dissolved contaminants may be emitted
 to  the atmosphere.  The raw waste  contains  a wide  range  of  volatile orga-
 nics,  as  well  as dissolved  inorganics, acids, and  bases.  Oxidation-
 reduction  reactions and changes  in pH in the redox and neutralization  sys-
 tems  result  in the  formation and potential  volatilization of partially
 oxidized  organic species  as  well as inorganic gases  such as  ammonia,  amines,
 and H2S.   Further,  in  the biological  treatment  system, the  emission poten-
 tial  is  enhanced by the aeration of the  liquid.  Here, volatile  organic
 matter remaining dissolved  in  the  water  as  well as products  of  biological
 degradation  of these organics  (e.g.,  amines, ammonia, aldehydes,  ketones,
 alcohols,  and  H^S), may be  released to the  atmosphere.

     Due to  the  widely  varying sources of waste handled  by this  facility,
 the nature and composition of the waste  varies extensively.  Wastes received
 at the aqueous waste treatment system include such materials as  the fol-
 lowing:  acids and alkaline  solutions, some  of which contain heavy metals;
 aqueous solutions containing various organic contaminants; and water conta-
minated with any of a number of  potentially  hazardous materials  such as
phenol, PCB, or  heavy metals.

     Because of  this vast variation in waste composition, atmospheric emis-
sions from this  sytem cannot be predicted based on the concentrations of
specific components of  the waste, and a  sampling and analysis program for
characterizing the emissions cannot be designed for specific chemicals in
                                    122

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the entering waste streams.   Rather, the prediction of emissions and the
design of a sampling program must be comprehensive and generic in nature.
Emissions considered must include those categories of classes of materials
most likely to be emitted based on (1) their presence in substantial concen-
trations, either because they are major constituents of the types of waste
materials typically treated, or because they are typically formed during
biological degradation of these wastes; and (2) their volatility and diffu-
sivity.
                       Emission Estimating Methodology


     A methodology has been developed for estimating atmospheric emissions
from aqueous waste ponds and lagoons based on the concentrations, volatili-
ties (as determined by vapor pressure and activity coefficient,  or Henry's
law constant), and diffusiyities of the wastewater contaminants.  The metho-
dology is founded upon basic two-phase mass transfer theory,  and preliminary
values for empirical constants of the methodology's mass transfer expression
have been developed from data reported in the literature.   Work dealing
specifically with the evaporation of volatile components of aqueous waste
provided limited data for the computation of wastewater atmospheric emission
rates (Bondurant 1973, Englebrecht 1961, Fruman, Gaudy 1961,  Ledbetter 1978,
Thibodeaux 1971 and 1978, and Tischler).  However, a great deal  of data,
useful for determining mass transfer rates, has been reported in association
with related subjects such as evaporation from spills (Wu), evaporation of
water from exposed surfaces (Liss 1973, Harbeck 1962), evaporation of compo-
nents of dilute solutions (Dilling 1977), dissolution of gases into the
ocean (Broeker 1974, Liss 1974, National Academy of Sciences  1976, Schooley
1969, SI inn 1978), dissolution of oxygen into water (Owens 1964), and gas
scavenging by rain (Hales 1972).

     The basic premise of the methodology is that the rate of emission of
dissolved materials from the surface of ponds and lagoons is  a function of
the driving force for mass transfer across the water-air interface.  The
main bodies of the water and air phases are assumed to be well mixed, so
that the water-air interface, considered as a two-layer film, is assumed to
offer the primary resistance to the transfer of mass from the liquid to the
gas phase, resulting in the concentration profile depicted in Figure 2.

     The transfer of mass across the interface may be expressed by applying
Pick's first law of molecular diffusion to the two-layer situation as fol-
lows:

                  F=KAC=kL(CLB-CLI)=kG(CGI-CGB);

where F is the interfacial flux of mass per unit of surface area,  k,  and kr
are the liquid- and gas-phase mass transfer coefficients, and C represents
the solute concentration in the bulk liquid (LB), liquid interface (LI), gas
interface (GI), and bulk gas (GB).  Further, the liquid- and gas-phase mass
transfer coefficients may be expressed in terms of molecular diffusivity
(D), and the thickness of the interfacial film (Z) as follows:


                                     123

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                                   FIGURE 2

                CONCENTRATION GRADIENT FOR MASS TRANSFER ACROSS
                            THE WATER-AIR INTERFACE"
             BULK
             LIQUID
LIQUID
FILM
GAS
FILM
BULK
GAS
                                                       'GB
Figure Notation

     C -- Solute Concentration
    LB — Bulk Liquid
    LI -- Liquid Interface
    GI -- Gas Interface
    GB — Bulk Gas
     Z -- Film Thickness
                                    124

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                                   k =
The gas film interface concentration may be expressed in terms of the liquid
film interface concentration, using an appropriate partition coefficient,  M,
assumed to be the Henry's law constant or the product of the solute's acti-
vity coefficient and vapor pressure, as follows:
Substitution into the expression for flux,  assuming the bulk air phase
concentration equals zero, and simplifying,  yields the following expression
for transfer of mass across the water-air interface:

                                            kl
                         F = k,C1Q (1 -      L    *
                              1WLB Vi    kGM + kL }

The liquid film thickness is not highly variable (National Academy of Sci-
ences 1976), and the liquid diffusivity, which is a function of the system
temperature and the solute molecular weight and inter-molecular attraction,
may be assumed to be fairly constant for the range of conditions and solutes
of concern.  Thus, based on published data (National Aceademy of Sciences
1976, Liss 1973 and 1974, Broeker 1974, Thibodeaux 1978, Schooley 1969,
SI inn 1978, Owens 1964, Hagbeck 1962), a value may be derived for k.  of
approximately 3 to 5 X 10   cm/sec,   the variation in the gas phase mass
transfer coefficient is much greater, due to the greater variability of gas
phase diffusivities and because of the sensitivity of the gas film thickness
to environmental conditions, particularly wind speed.  Based on limited
published data (Liss 1974, Schooley 1969), a first approximation of a mean
value may be derived for the gas film thickness of 0.26 cm.

     Emissions from aerated surfaces may be treated in a manner similar to
the above treatment for quiescent surfaces, by accounting for the increased
surface area created by the aerators and the enhancement of the gas film
mass transfer coefficient.  Data are available for estimating the increased
surface area created by aerators (Bondurant 1973), and estimates of mass
transfer coefficients for such systems have been developed (Thibodeaux
1978).

     As present, however, emission rates may not be predicted with confi-
dence for either quiescent or aerated surfaces of wastewater ponds and
lagoons because of the paucity of data for determining mass transfer coef-
ficients for these systems.   One purpose of the proposed atmospheric emis-
sion sampling program is to furnish these data.
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                                   PROCEDURE
                                   Sampling


      A number of sampling methodologies were considered for use in the
 emission characterization program.   These included upwind-downwind sampling
 (Kolnsberg 1976a), a quasi-stack technique (Kolnsberg 1976b),  emission
 profiling (Cowherd 1977), source enclosure methods (Zimmerman  1978,  Adams
 1979), and vapor space analysis techniques.   The program which has been
 developed involves the use of a vapor space analysis technique in  conjunc-
 tion with an enclosure sampling method for the non-aerated  aqueous waste
 lagoons, and emission profile sampling for the aerated ponds.


 Vapor Space Analysis


      The vapor space analysis is used to identify and determine  the  concen-
 trations of species in the vapor phase at equilibrium with  the aqueous
 solutions of concern.   This analysis  provides  for the identification of
 solutes  which are present in solution at sufficient  concentration  and which
 are  sufficiently volatile to be released from  the pond or lagoon into  the
 air  above it.   Further,  since the vapor phase  equilibrium concentrations of
 the  solutes are determined, this analysis provides a direct indication of
 the  driving force for mass transfer because  it identifies and  quantifies the
 evaporative potential  of the volatile species  which  are of  interest  and is
 not  confounded by interferences of other materials present.

      The first step in performing a vapor space  analysis  is  collecting a
 composite liquid sample  from the pond or lagoon  of interest.   The  sample
 collection  container is  filled  completely and  sealed tightly to prevent the
 evaporation of volatile  components during handling.   In the  laboratory, the
 sample is thoroughly mixed and  an aliquot of approximately  800 ml  is trans-
 fered  to  a  1  liter  flask with a side  arm.  (The  flask should be at least
 three-quarters  full).  The flask is sealed tightly with  a septum, the con-
 tents are agitated,  and  the  flask is  placed in a  70°F  constant temperature
 bath.  After allowing  sufficient  time  for equilibrium  between the liquid and
 gas phase at 70°F to be  reached,  a micro-liter syringe  sample of the vapor
 is withdrawn.

     The  gas sample  is syringe  injected  into the  carrier gas stream of the
 (Organic  Vapor Analyzer)  gas chromatograph (GC).   After the chromatogram is
 obtained, the GC column  is  backflushed directly to the  flame ionization
 detector  chamber, providing a quantitative measurement of any residual
compounds in the gas sample.  In  this way, the total concentration of orga-
nic material as well as the concentrations of individual species may be
determined.  To ensure that the vapor samples analyzed represent equilibrium
conditions, gas chromatograms will be run at 15 minute intervals, after an
 initial equilibrization period of one hour, until constant results  are
obtained  for successive samples.


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Surface Enclosure Sampling


     Surface enclosure sampling provides data for the determination of the
dynamic rate of transfer of material from the liquid surface of a pond or
lagoon into the air above it.  To obtain a dynamic sample of this air, an
air-tight surface enclosure, with a sample outlet and fresh air inlet at
opposite ends, is floated on the surface of the water.   An air-tight enclo-
sure is created by covering one end of the opening of an inflated truck
innertube with translucent plastic, sealed to the tube's perimeter.  As the
air sample is withdrawn at a constant rate through the sample outlet, puri-
fied sweep air enters the opposite end of the enclosure through an inlet
tube which projects down to just above the liquid surface.   The sweep air is
purified prior to entering the enclosure by passing through a dual adsorp-
tion column of activated carbon and XAD2, when sampling for organic vapors,
and through appropriate absorption solutions, when sampling for ammonia,
amines, and H2S.

     For organic vapor analyses, the sample air is drawn directly into the
OVA.  The gas sampling rate to the OVA is adjusted, while monitoring the
total organic vapor concentration, until a concentration of 10-20 ppm is
obtained.   This concentration is high enough for accurate measurement and
low enough so as not to cause vapor phase resistance to mass transfer (the
equilibrium partial pressure of volatile species will correspond to a con-
centration much greater than 20 ppm).

     Once the desired flow rate is determined, sampling at this rate is
continued until a steady state condition is reached, as indicated by a
stable concentration reading.  At this point, the flow rate and concentra-
tion of total organic compounds are noted, and a portion of the sample being
drawn to the OVA is injected into the GC column for identification and
quantification of the organic species present.  A surface-based emission
rate is determined from the data obtained by dividing the product of the gas
sample rate and the measured concentration by the area of the liquid surface
exposed to the inside of the enclosure.   That is:

     Emission Rate Per Unit of Surface Area = (Gas Sampling Flow Rate) X
     (Sample Concentration)/(Surface Area Covered by Enclosure).

The dynamic emission rate can be correlated to equilibrium vapor phase
concentration data, determined via vapor space analysis, for a determination
of the resistance to mass transfer posed by the liquid and gas interfacial
films, or, conversely, the interfacial mass transfer coefficients.


Profile Sampling


     Because the surface enclosure method cannot be used where the surface
is disrupted by the action of aerators,  an alternative sampling approach
employing a perimeter or downwind air sampling technique must be used at the
aerated biological oxidation ponds.  For this program a perimeter profile
sampling technique was selected.


                                    127

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      In profile sampling, the concentrations of contaminants are measured at
 an array of points in the source emission plume as it passes some downwind
 location; in this case, the source perimeter.   From these measurements,  a
 vertical plume concentration profile can be developed.   Initially,  screening
 is performed, using the total organic vapor analysis capability of the  OVA
 to determine the necessary extent of the vertical  sample point array and the
 sample point spacing needed to develop a meaningful profile.   Then,  at  each
 sampling point, samples are drawn into the OVA for total organic vapor
 analysis and for GC determination of the organic components.   Additionally,
 samples are collected in appropriate absorption solutions for analyses  of
 inorganic vapor emissions.   An upwind sample is taken in each case  so that
 background contaminants levels can be accounted for.

      The vertical  plume profile is plotted and integrated over the  vertical
 extent of the plume in order to determine the  average plume  concentration.
 The emission rate per unit of surface area can then be  determined by multi-
 plying the average plume concentration by the  amount of diluting wind which
 crossed a one unit wide vertical  cross section of  the plume  (i.e., wind
 speed times the vertical extent of the plume)  and  dividing by the pond
 surface area over which the one unit width column  of wind traveled  (i.e.,
 pond width).   That is:

      Emission Rate Per Unit of Area = Average  Plume Concentration X
      Wind Speed X  Vertical  Extent of the Plume r Pond Width.
                                Sample Analysis


Organic Vapor Analysis


     A portable Organic Vapor Analyzer  (OVA) produced by Century Systems
Corporation will be used for determining the total concentration of organic
material and the concentrations of specific organic compounds in gaseous
emission samples.  The portable OVA is  designed to measure small concentra-
tions (1-10,000 ppm) or organic material in air.  The OVA uses a hydrogen
flame ionization detector (FID) which has been used for many years as .a
detector for organic compounds, and it  has a built-in gas chromatograph for
separation of the components of sampled gases.   The portability of the OVA
coupled with its intrinsic safety make  it an ideal instrument for the pro-
posed field work.  (The OVA is certified intrinsically safe by Factory
Research Corporation for Plot One, Division One, Groups A, B, C, and D
hazardous environments).

     The FID system used in the OVA consists of a diffusion flame of pure
hydrogen which is free of ions and is thus nonconducting.   However, when a
sample of organic material  is introduced into the flame, ions are formed and
the flame becomes conductive.   The conductivity of the flame can then be
measured.   The amount of conductivity that the flame exhibits with the
                                     12c

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introduction of organic compounds is related to many parameters, but is
thought to be primarily based on the number of carbon atoms present and the
efficiency of combustion.

     In the typical laboratory FID, the sample to be analyzed is entirely
mixed with the hydrogen prior to introduction to the burner.   This premixing
of the sample with the hydrogen does not occur in the OVA.   In the OVA, the
sample is brought in with the combustion air.   The sample contained in the
combustion air is introduced into the combustion/detection chamber through a
porous bronze filter which disperses the air and organic compounds around
the hydrogen flame.

     This method of introducing the sample to the hydrogen flame modifies
the typical ion formation process and consequently changes the OVA's FID
response to various compounds from that of a conventional FID.  In the usual
laboratory FID, a normal C3 would have a response of three times the methane
response (for the same concentration)and a normal Cfi would have a response
of six times that of methane.  The OVA FID, however, has a response for
nearly all commonly encountered hydrocarbons of between 50% and 150% the
response for methane.

     The precise reason for the difference in response between the OVA and
other FID's has not been completely determined.  One hypothesis is that the
size of the reaction envelope and the energy available from the hydrogen
flame are altered by intoducing the sample at the periphery of the flame
reaction zone.   This allows for less contact time, which reduces the number
of ions formed, and consequently changes the response mechanism.

     The Century Systems OVA, which will respond to almost all organic
compounds, may be calibrated with hexane.   However, since the response of
the OVA differs somewhat for the various compounds, it is best to calibrate
the instrument with the organic compounds that are expected to be encoun-
tered in the field.  The basic method for developing a calibration curve
consists of recording the response of the OVA to a range of concentrations
of the expected organic gases.  The OVA responses to the known hydrocarbon
concentrations are then plotted to obtain a calibration curve for the test
mixture.

     The compositions of the test mixtures used for initial calibrations
will  be determined from the presence of volatile organics in the wastes
received and from GC/mass spectrometer analyses of equilibrium vapor samples
of pond and lagoon wastewater.  During the sampling program, any additional
peaks which occur, which were not present in the original test mixtures,
will  be evaluated based on their relation to known peak locations and
heights,  to the extent possible.  Recurring unknown peaks will be evaluated
by performing additional GC/mass spectrometer analyses, as needed.


Inorganic Vapor Analysis


     Inorganic gases do not contain carbon atoms and, therefore, they are
not detected by the OVA FID.  Further, because the anticipated  inorganic

                                    129

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constituents of waste treatment pond and  lagoon emissions are highly reac-
tive,- they are not well suited to analyses, such as GC/mass spec, which
require the collection of neat samples  in glass bombs or sample bags.
Therefore, absorption sampling will be  used for collecting air samples for
the analysis of inorganic vapor constituents by wet chemical methods.
Although many types of wash bottles are available for air sampling, impin-
gers are recommended for collecting readily absorbable gases which rapidly
dissolve in the washing liquid.  For the proposed program, a series of
Greenburg-Smith impingers are to be used.  A constant flow rate pump is used
to draw air through these impingers at a rate of up to 1 cubic foot per
minute (28 liters per minute) for the desired sampling duration (typically
30 to 60 minutes).  A 50 milliter aliquot of washing solution is typically
employed in each impinger.   Effective washing of the air by the absorption
solution is enhanced by the small diameter of the narrow end of the impinger
inlet tube (2.3 mm) and the proximity of the inlet to the base (5 mm).

     Examples of analytical  methods for the inorganic vapors of concern,
selected based on sensitivity and specificity (Leithe 19/1 and Ruch 1970),
are as follows:

          Ammonia - Indophenol Reaction (Leithe 1971)
                    Determination Method
                    Absorption Solution
                    Sensitivity
                    Interference
  spectrophotometri c
  0.01N H2SO.
  ppb range
  monoalkylamines
                    Nessler's Reaction (Elkins)
                    Determination Method
                    Absorption Solution
                    Sensitivity
                    Interference
  spectrophotometri c
  sulfuric acid
  3 ppm
  any material producing
  ammonia
                    As  Trichloramine  (Zitomer  1962)
                    Determination  Method
                    Absorption  Solution
                    Sensitivity
                    Interferences
  spectrophotometri c
  distilled water
  10 - 300
- amines
                   Phenol - Hypochlorite Reaction (Weatherburn
                   1967)
                   Determination Method
                   Absorption Solution
                   Sensitivity

                   Interferences
  spectrophotometri c
  distilled water
  suitable for air pol-
  lution work
  amines
                                    130

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          Aliphatic Amines - Acylation with Cinnamic Anydride
                   (Hong 1968)

                    Determination Method -  spectrophotometric
                    Absorption Solution  -  acetonitrile solution
                    Sensitivity          -  ppm level
                    Interferences        -  none of concern

          Aromatic Amines - With 9-Chloroacridine (Stewart 1969)

                    Determination Method -  spectrophotometric
                    Absorption Solution  -  ethyl alcohol
                    Sensitivity          -  suitable for air pollu-
                                           tion work
                    Interferences        -  primary amines

          Sulfide - N,N - dimethyl-p-phenylenediamine (Jacobs
                    1967)

                    Determination Method -  spectrophotometric
                    Absorption Solution  -  alkaline cadmium
                                           sulfate
                    Sensitivity          -  ppm range
                    Interferences        -  none of concern

          Hydrogen Chloride - Silver Nitrate Titration (Hanson
                    1965)

                    Determination Method -  titration
                    Absorption Solution  -  distilled water
                    Sensitivity          -  2.5 ppm
                    Interferences        -  halides
                         DISCUSSION AND CONCLUSIONS


     The proposed sampling program will provide a comprehensive characteri-
zation of the organic and inorganic vapor emissions from aqueous hazardous
waste physical/chemical treatment lagoons and aerated biological oxidation
ponds.  Further, the organic vapor emission data will be used to develop
organic vapor emission factors for wastewater ponds and lagoons.

     The use of complementary sampling and analysis methods will provide for
the verification of results.  Further, complementary sampling will furnish
data for determining both the driving force for mass transfer across the
water-air interface and the dynamic mass transfer rate (emission rate), so
that empirical mass transfer coefficients can be evaluated.

     The driving force for mass transfer can be determined from the equili-
brium vapor concentration data from the vapor space analyses.  A further
                                     131

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 value of this analysis technique is that it provides a relatively  concen-
 trated gas sample so that organic components of concern can  be  detected  and
 measured accurately.

      The dynamic emission rate may.be assessed via  surface enclosure,  expo-
 sure profiling,  or upwind-downwind sampling.   Surface enclosure sampling
 provides certain advantages over sampling performed at the perimeter or
 downwind of an aqueous pond or lagoon.   The concentrations of the  components
 of interest in the gas sampled can be varied by varying the  rate of enclo-
 sure sweep gas,  and a concentration suitably high for accurate  instrumental
 analysis can be  obtained.   In  contrast,  concentrations at perimeter or
 downwind sampling points  will  be much lower.   Further,  the concentrations of
 downwind samples are affected  by the wind speed and direction and  by disper-
 sion,  which is a function of atmospheric stability.   These meteorological
 parameters introduce sources of error in relating measured downwind concen-
 trations to surface emission rates.

      On the other hand, by enclosing the liquid surface, the experimenter is
 creating an artificial  situation and must guard against the  introduction of
 errors due to consequent  effects.   The enclosure will  stifle the natural
 escape of heat from the surface,  so the  sampling period must not be of so
 long a duration  nor the sweep  gas  of so  low a flow  rate as to allow heat to
 build  up within  the enclosure.   Further,  the  sweep  gas  rate must be great
 enough that equilibrium between the components  in the  liquid and vapor phase
 is  not reached,  as this would  result in  the computation of artificially  low
 emission rates.   However,  the  rate  of sweep gas  must  not be so  high as to
 disturb the liquid surface,  artificially inducing volatilization,  nor  so
 high that the concentrations of gaseous  contaminants  are too low to be
 measured accurately.

     Where  the surface enclosure technique  cannot be  used because of the
 disturbance of the liquid  surface  from the  action of aerators,  an alter-
 native  method must be  employed.  For  this purpose, profile sampling at the
 source  perimeter  offers certain advantages  over  upwind-downwind  sampling.
 Since  samples are  obtained  closer to  the  source  (i.e.,  at the source peri-
 meter  rather  than  at  some downwind  distance), the concentrations of conta-
minants  from  the  surface will be higher and,  thus, can  be measured more
 accurately.   Further, although the  results  are sensitive to wind speed and
direction and atmospheric dispersion, the effects of these factors are. not
as great as they are for the upwind-downwind method.
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          nation of Primary Aromatic Amines with 9-Chloracridine, Anal.
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Thibodeaux, L.J., R.B. Estridge, and B.G. Turner, 1971, "Measurement of the
          Relative Volatilization of the Water-Mi scible Fractions in an
          Aqueous Effluent," AIChE Symposium Series No. 124, Vol. 68, pp
          169-179.

Thibodeaux, L.J.  and D.G.  Parker, 1978, AIChE Symposium Series No. 156, Vol
          72, pp. 424-434.
                                    134

-------
Tischler, L.F. and J.F. Malina, Updated, "Evaluation of the Potential for
          Air Stripping of Hydrocarbons During Activated Sludge Wastewater
          Treatment," University of Texas/Engineering-Science, Austin,
          Texas.

Weatherburn, M.W., 1967, "Phenol-Hypochlorite Reaction for the Determination
          of Ammonia," Anal.  Chem., Vol. 39, No.  971.

Wu, J.M. and J.M.  Schroy, "Emissions from Spills," Monsanto Company, St.
          Louis, Missouri.

Zimmerman, P., 1978, "Procedures for Conducting Hydrocarbon Emission Inven-
          tories of Biogenic Sources and Some Results of Recent Investiga-
          tions," in:  Emission Inventory/Factor Workshop, Volume 2 (EPA-
          450/3-78-042b), Office of Air Quality Planning and Standards,
          Research Triangle Park, N.C., May 1978, pp.  25-1 through 25-32.

Zitomer, F. and J.L. Lambert, 1962, "Spectrophotometric Determination of
          Ammonia as Trichloramine," Anal. Chem., Vol. 34, No. 1738.
                                     135

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                  RESULTS OF FUGITIVE EMISSION MEASUREMENTS  AT

                       REFINERIES AND CURRENT ACTIVITIES IN

                              PETROCHEMICAL UNITS

                                       by

                               Donald D.  Rosebrook

                        Radian Corporation,  Austin,  Texas


                                    ABSTRACT


          Final  results of  fugitive emissions  monitoring  in petroleum
 refineries  are presented as a series of  emission factors  for  valves, flanges
 pump  seals,  compressor seals,  relief valves and  drains.   The  emission factors
 appear  to be dependent on the type  of service  in the line,  consequently the
 emission factors have  been  developed for gas/vapor, light liquid and heavy
 liquid  service.   No dependency on temperature, pressure or  line size was
 noted.  Extensive quality control data allowed the  calculation of confidence
 intervals for all emission  factors.   Correlations between a hydrocarbon
 "sniffer" value  and measured  mass emissions  rates in pounds per hour are
 given.

          Currently EPA is  sponsoring studies  in the synthetic organic chemi-
 cals manufacturing industry.   The. current program includes  both screening and
 sampling selected valves  and  pumps  and screening all "baggable" sources in a
 variety of chemical manufacturing units.  The  screening studies are being
 conducted by four separate  EPA contractors, Radian, PEDCo,  TRW and Acurex
with Radian  doing all  data  reduction.  Screening data for target chemicals are
being obtained from at  least  two different  sites if possible.  Sampling data
 is being obtained for  three chemicals at two sites each.  Correlations between
 the hydrocarbon  "sniffer" value and  the mass emission rate  are being developed.
Studies of the effect  of maintenance  on leak rate for valves are also being
conducted.   Hydrocarbon "sniffer" response  factors are being developed for
over 100 chemicals with respect to known concentrations of methane.
                                      136

-------
          The intent of this paper is twofold:  first,  to discuss the final
results of the recently completed fugitive hydrocarbon emission portion of an
EPA sponsored Petroleum Refinery Assessment Program.  Secondly, to discuss
a program which is just beginning to study fugitive emissions in various
processes of the synthetic organic chemical manufacturing industry (SOCMI).
Thus, in Part 1 of this paper we will be discussing final results, while in
Part 2 we will be discussing philosophy and design.

          Part 1;  Results of Fugitive Hydrocarbon Emission Measurements in
          the Refining Industry

          Study Design

          The study was designed to include a representative portion of the
United States petroleum refining industry for an examination of fugitive
emissions from point sources including valves, pump and compressor seals,
drains, relief valves and flanges.  In the design of the study, the variables
of refinery age, refinery size, and refinery location were carefully con-
sidered.  Thirteen refineries across the United States were selected for the
study.  They ranged from less than ten years old to nearly 100 years old.  The
U. S. was divided into four primary geographical areas, that is, the Northeast,
Southwest, Midwest, and the West coast, where the bulk of the petroleum
refining activity is conducted.  At least three refineries were chosen in each
of these geographical areas and within each area at least one new and one old
refinery and one large and one small refinery were selected.  For each fugitive
source to be sampled, several variables were considered to be important in
selecting those fittings to be tested.  Table 1 shows the type and range of
variables which were used in developing the sampling matrix for each type of
fugitive emission source.  Those fittings selected for inclusion in the study
were chosen from P&ID diagrams, sight unseen, by Radian engineers, then lo-
cated in the refinery, screened with a portable hydrocarbon detector, and
eventually bagged or tented for actual mass emission rate measurements.

          Results

          Table 2 presents the results of the fugitive emission measurements
by source type.  As indicated in the table, the stream service for the various
sources proved to be the major source of variation.  Types of service were
divided into gas vapor streams, light liquid or two-phased streams and heavy
liquid streams.  The dividing line between light liquid and two-phased streams
and heavy liquid streams proved to be at the approximate volatility of kero-
sene.  Valves in hydrogen service were streams which were at least 50 percent
hydrogen with the remainder being hydrocarbons.  Open ended valves were also
singled out.  These are valves primarily used for quality control sampling
purposes within a refinery unit.  The values shown in the table for pump and
compressor seals are expressed per seal rather than per pump or per compressor.
The emission factor for compressor seals was the largest of any of the
emission factors and the percent of compressor seals leaking was  the largest
of the percentages for any of the sources.  Conversely, the percent of flanges
leaking was the smallest of any of the sources and its emission factor was
also the lowest.  Expanding this data to an entire refinery would show that
valves are the most significant of all of the leaking sources because of  their
number, while flanges are the least significant of all leaking sources.
                                      137

-------
                    TABLE 1.  RANGE OF CHOICE VARIABLES FOR
                              SCREENED BAGGABLE SOURCES
 Baggable Source
  Choice Variable
      Variable Ranges
    for  Screened  Sources
 Valves
 Flanges
Pump Seals
Compressor Seals
Drains

Relief Valves
 Pressure
 Temperature
 Fluid State
 Service
 Function
 Size

 Pressure
 Temperature
 Fluid State
 Service

 Size

 Pressure
 Temperature
 Capacity
 Shaft Motion
 Seal Type
 Liquid  RVP

 Pressure
 Temperature
 Shaft Motion
 Seal  Type

 Lubrication Method
 Capacity

 Service

Pressure
Temperature
Fluid
 -10 - 3000  psig
 -190 - 925°F
 Gas, Liquid,  2-phase
 In-line,  Open-ended
 Block,  Throttling, Control
 0.5 - 36  inches

 -14 - 3000  psig
 -30 - 950°F
 Gas,  Liquid,  2-phase
 Pipe,  Exhanger, Vessel,
  Orifice
 1-54  inches

 0 - 3090  psig
 0 - 800°F
 0 - 100,000 gpm
 Centrifugal, Reciprocating
 Mechanical  Seal, packed seal
 Complete  range

 0 - 3000  psig
 40  -  300°F
 Centrifugal, reciprocating
 Packed, labyrinth,
  mechanical
 Hydrocarbon lubricant
 0.06 - 66.0 MMSCFD

Active, Wash-up

 0 - 1350 psig
40 - 1100°F
Gas, Liquid
                                      138

-------
TABLE 2.  SUMMARY STATISTICS AND ESTIMATED VAPOR EMISSION FACTORS
          FOR NONMETHANE HYDROCARBONS FROM BAGGABLE SOURCES
Source Type
Volvos
One Vapor Stream
Light Llquld/Two-Fliaae
Heavy Liquid
Hydrogen
O|ien-Ended Volveu
Light Liquid Streams
Heavy Liquid Streams
lira Ins
Flangea
Relief Valvca
Cowprcaaora
Hydrocarbon Service
Hydrogen Service
Niwlx-r
Screened

563
913
485
135
129
470
292
257
2094
148

142
83
Nimher
Leaking

154
330
32
59
30
296
66
49
62
58

102
69
I'l-ICl'Ut
Leaking

27
36
6
43
23
63
22
19
3
39

71
63

.4
.1
.6
.7
.3
.0
.6
.1
.0
.2

.8
.1
95Z Confidence
Interval for
Fcrccnt l.rnklng

(2*.
(33.
( 4,
(35.
(16,
(59,
(18.
(14,
( 2.
(31.

(64,
(75,

3D
39)
9)
52)
3D
67)
27)
24)
4)
47)

79)
91)
Knlaeloii
Factor
F.vtlautte
(lb/hr/Bource)

0
0
0
0
0
0
0
0
0
0

1
0

.059
.024
.0005
.018
.005
.25
.046
.070
.00056
.19

.4
.11
95Z Confidence
Interval fur
Ealaalon Factor
(Ib/lir/aource)

(0.
(0.
(0.
(0.
(0.
(0.
(0.
(0.
(0.
(0.

(0.
(0.

030.
017.
0002
007.
0016
16,
019.
023.
0002
070.

66,
05,

0.110)
0.036)
. 0.0015)
0.045)
. 0.016)
0.37)
0.11)
0.20)
, 0.0025)
0.49)

2.9)
0.23)

-------
           The distribution of leak rates was another important result of the
 study.  The study results indicate that the majority of sources leak at a very
 low level and that the significant contributions to the emission factor come
 from those few sources leaking at high rates.  This is illustrated in Table 3
 for valves in gas/vapor service, where it is shown that of all the valves in
 the study, seven of them leaked at greater than one pound an hour and that
 these seven valves contributed 70 percent of the total mass of the leak.
 Figures 1 and 2 provide the same information in graphical form relating screen-
 ing value to percent of sources and percent of emissions, respectively.

           Figure 3 shows a nomograph for predicting total nonmethane leaks
 from screening values for valves in gas/vapor service.   This demonstrates that
 within reasonable confidence limits, the screening value obtained with a hydro-
 carbon detector can be correlated to mass emission rates for a group of valves
 This correlation should prove to be a valuable tool for both maintenance and
 regulatory activities.  The nomograph in Figure 4 demonstrates the same type
 of relationship for valves in light liquid service.  Similar nomographs have
 been developed for all of the source types investigated during this program.
 It should be stressed that these nomographs are not meant for direct point by
 point correlation of single valves,  but rather apply to the mean of a number of
 sources.

           Correlations

           In Table 4 the correlation coefficients between operating/design
 variables and leak rate are presented.   As you can see,  the correlation
 coefficients presented in the table  are by and large rather small.   They  are
 however,  statistically significant  in those cases where they have been denoted
 by an asterisk.   Even though some of the correlations were  statistically  sig-
 nificant,  no discernible pattern emerges relating leak  rate to process/design
 variables for all sources.

           Figures 5-7 are schematic plots demonstrating the lack of  varia-
 tion in emission rates in relation  to some of  the parameters examined  in  the
 study.  Figure 5 shows the  data  for  pumps  with single and double  seals, and
 indicates  little difference in the mass  emission  rate on  the basis  of  seal
 type.  However,  there may be some service  severity  factor which  causes  the
 apparent  lack of correlation.  A service severity factor  was not  anticipated
 during the study,  thus no data are  currently available  for  ready  review.   in
 Figure 6  the  same  type of information for  single  seals  and  double  seals is
 presented  for  compressors.   Once  again  the  cells  overlap  and the means  are
 extremely  close  together.   Figure 7  examines the  block  and  control  function of
 valves, and  again,  it  is  demonstrated that  there  is very  little difference
 between the mass  emission rates  in any  type  of  stream between  block  and control
 valves.  Figure  8  shows  the  relationship between  leak rate  and diameter for
 compressor seals,  and  again  it should be noted  that  the correlation  is poor.
 Figure 9 shows leak rate  versus pressure for compressor seals  and again the
 relationship  is  poor.

          Finally,  in  Figure  10  the variation  in  a given  leak  rate as  the
 function of time  is presented.  This  figure demonstrates  the reason for wide
 confidence intervals  in many of the  sources and illustrates  the difficulty
which will be encountered in both maintenance and regulatory activities.  As
 one can see on the right  hand portion of the figure, the  leak rate in pounds


                                      140

-------
TABLE 3.  DISTRIBUTION OF NONMETHANE
          HYDROCARBON LEAK RATES
Values, Gas/Vapor Streams
(563 Screened)

Leak Range
(Ib/hr)
1.0
0.1 - 1.0
0.01 - .1
0.001 - 0.01
0.00001 - 0.001


No.
7
18
43
49
37
154
Leaking Sources
% of
Leaking
Sources
4.6
11.7
27.9
31.8
24.0
100%
Within Range
% of Total
Sources
Screened
1.2
3.2
7.6
8.7
6.6
20.3%
Total
Total
Leakage
(Ib/hr)
17.7654
5.9187
1.4867
0.2052
0.0133
25.3893
Leakage Within Range

% of Total
Source of Leakage
70.0
23.3
5.9
0.8
0.1
100%

-------
 o
   90





   80





   70





   60





S  50

«^
c
t>

i;  40
u
a.


   30





   20





   10
                        Upper Limit of 951 Confidence  Interval
                                      Estimated Percent of Sources



                                     x
                   Limit of 95*

              Confidence  Interval
         I  111   t
                        I	I
       1  2 345 10      50 100       1,000      10.000     100.000    1,000.000




                    Screening Value (ppmv) (Logi0 Scale)





       Percent of  Sources - indicates the  percent of sources with screening

                             values greater than the selected value.
Figure  1.   Cumulative Distribution of Sources and Total Emissions

            By Screening Values  for Valves  -  Gas/Vapor  Streams

-------
u>
                           100


                            90


                            80
                         «•
                         a
                         -  70
                         «•

                         Ul
                         M  60
3  50
2
o  40
*J
C

i  3°
c.

   20


   10
                                   Estimated Percent of
                                   Total  Mass Emissions
                                 I  i i
                                               j	i
                                                            Upper Limit of 901
                                                            Confidence Interval
                                                                  Lower Limit of the
                                                                  901 Confidence Interval
                              1  2 345  10     50 100       1,000     10.000     100.000


                                              Screening Value (ppav) (Logjo Scale)
                                                                 1,000.000
                             Percent of Total Mass Emissions - indicates the percent of total  emissions
                                                                  attributable to  sources with  screening
                                                                  values  greater than the selected value.
                             Figure  2.   Cumulative Distribution of Source  and Total  Emissions By
                                         Screening Values for Valves - Gas/Vapor Stream

-------
   0.07
£ 0.06
   0.05
 e
 e
   0.04
•«
c

£ 0.03
a
2 0.02
o
  0.01
      m Lt»k Ritt) • -7.0 * 1.23 Logt, (fUx Scrtenlnj Vtlue)
 CorttUrion Coefficient • 0.76
 Number of Dm ?«1rj • 0.79
 Standard Error of E»t1mzt* • 0.78 Log>t (KM Leak Rats)
     lias Correction ftaar • 4.31
                             /
                               /
                /
                                   /
                                     /
                       /
                        /
                                           /
                                             /

                                                /
                                                  /
                                                    /
                                                        Upper Licit  of SOI Confidence
                                                     / Interval  for Msan
          /
             /
               /
/
                   /
                     /
                       /
        /
                           /
                                                        Mean
                                       Lower Lir.it  of SOS Confidence
                                   .   Interval  for Mean
          1,000
            s.ooo
10,000
            Maximum Screening Value (ppmv as Hexane)
         Using J.W. Sacharach TLV Sniffer at the Source.
        Figure 3.   Nomograph  for Predicting Total  Nonmethane
                     Hydrocarbon Leak Rates from Maximum  Screening
                     Values - Valves,  Gas/Vapor  Streams
                                      144

-------
   0.07

 w
JS
^»
 «•
^0.06
 •
«^
£

 2 0.05
9 0.04
•5 0.03
-0.02
   0.01
                        Upper Limit of 901 Confidence
                        Interval for Mean
                                                  Mean
                        Lower Limit of 901 Confidence
                        Interval for Mean
               I    t   I    I	I    I    I    I    I
         1.000
5,000
10.000
           Maximum Screening Value (ppmv as Hexane)
         Using J.U. Bacharach TLV Sniffer at the Source.
        Figure 4.  Nomograph for  Predicting Total Nonmethane
                    Hydrocarbon Leak Rates from Maximum Screening
                    Values  - Valves, Light Liquid/Two-phase Streams

-------
           TABLE 4.  CORRELATIONS BETWEEN CONTINUOUS VARIABLES AND LOG    LEAK RATE
LINE STROKE
PRESSURE TEMPERATURE AGE SIZE DIAMETER AREA RPM CAPACITY LOAD LENGTH
VALVES
Gas/Vapor Streams
Light Liquid Streams
Heavy Liquid Streams
Hydrogen Service
Open-Ended
PUMP SEALS
Light Liquid Service
Heavy Liquid Service
FLANGES
COMPRESSOR SEALS
Hydrocarbon Service
Hydrogen Service
DRAINS
RELIEF VALVES

.230*
.103'
-.351'
-.088
.236

.088
,097
.072

.346*
.398*
-
.045

.077
.051
.144
.129
.212

-.012
-.098
.021

.218*
.312'
-.108'
.096

.263' .150' - - - -
.096 .143* - - -
.220 .046 - - - -
-.531* .288* - - - -
.230 -.078 - - - -

.062 - .021 - -.064 - -
,237 - .128 - -.182
-.180 .336" - - -

.105 - .278* - -.143° -.138 -.087 -.012
.052 - .343* - -.034 .218 -.099 -.074
- -.039 -.191 -
- -.075 -
•Correlation Coefficient  statistically different  from zero (P> .90).
3Log10 RPM was correlated with  Iog10 leak rate.

-------
     2.00
    0.667
C£
nr
CQ
   -0,667
    -2,00
UJ
£  -3.33
o
 CD

S  -4,67
   -6,00
N = 33
        N = 231
                         LIGHT LIQUIDS
                      DOUBLE       SINGLE
                       SEAL         SEAL
                                                  =  9
                                                        N = 54
                                                 HEAVY LIQUIDS
                                               DOUBLE      SINGLE
                                                SEAL        SEAL
                                                                       KEY
                                                                         : Detached Value (1 In 200)
                                                                       ~*
                                                                             Upper Quortlle
                                                                             Heon
                                                                             Median

                                                                             Lower Quortlle
                                                0 Outside Value (1 In 20)
                                                0
                   Figure 5.  Schematic Plot for Pumps by  Seal Variables

-------
    2.00
   0,833
  -0.333
    -1,50
    -2,67
CD
o
    -3.83
    -5.00
                                  • t
                                   t
                        N = 3  N =  76
                     HYDROCARBON STREAMS
                     DOUBLE        SINGLE
                                                  = 21  N = 22
  HYDROGEN  STREAMS
DOUBLE        SINGLE
                                                                     KEY
                                                                      * Detached Value (1 in 200)
                             Upper Quart lie
                             Mean
                             Median

                             Lower Quart lie
                         0 Outside Value (1 In 20)
                         0
     Figure  6.   Schematic Plot  for  Compressor Seals by  Single/Double Seal Variable

-------
l.UU



-0,333



i
> -1 R7
cu j. i \ji
— I
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KEY


j Detached Value (1 In 200)
p-i— - Upoer Quart Me
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	 Median

I-|-J Lower Ouartlle
1
1
0 Outside Voiue (1 in 20)
0





                                     ™*°««
Figure 7.  Schematic Plot for Valves by Block/Control Variable

-------
Ui
o
                UJ
                s
    1.6


    0,8


    0,0


   -0,3


   -1.1
                 CD



                 LD
                 O
                        t  A
ci> _2ti
                   -3,2*
                   -4.0
                                                      LEGEND:   A = 1 OBS, B = 2 OSS, ETC,

                                                      Correlation Coefficient (r) = 0.278

                                                      Number of Data Pairs        = 88
                         1,5
                2,0     2,5     3,0     3,5    4.0

                                   DIAMETER (INCHES)
,5    5,0     5,5    6.0
                                     Figure 8.   Leak Rate vs. Diameter -

                                                Compressor Seals, Hydrocarbon Service

-------
o:
    1.6
    0.8;
    0.0
   -o.s;
   -1.6;
 2-2.4
   -3.2
LEGEND:  A = 1 DBS,  B = 2 DBS,  ETC.
Correlation Coefficient (r)  = 0.346
Number of Data Pairs        = 102
   -4.0
   -4.8 ;
            0   40   80  120 160  200 240  280  320  360 400  440  480  520  560
                                     PRESSURE (PSIG)
                     Figure 9.  Leak Rate vs. Pressure - Compressor
                               Seals,  Hydrocarbon Service

-------
   0.028 •




I  0.024'
aa



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=  0.012 •




2  O.OC8-
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 *•-..
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                          ID - 15VA231
                                              * :

                                               #
                             1/27
                    DATE (Ofl. fiM£j
L31  2/22/3  I/  =1  '  ' *

        Figure  10.  Short-Term  Variation in

                     Leak Rate - Valves
                           152

-------
per hour varied by an order of magnitude over a period of approximately two
hours.  Such occurrences were not uncommon.

          Part 2;  Fugitive Emission Testing in SOCMI Process Units

          The second part of this paper deals with current work in various
SOCMI process units.  This work is being supported again by EPA, 1ERL both in
RTF and in Cincinnati and is being closely coordinated with OAQPS.  There are
essentially two programs being conducted simultaneously and in some cases in
the same production unit.  One of the programs is a fugitive emission screening
survey which will be further described here.

          The second is a program to determine the long and short term effects
of maintenance on valves and the occurrence and reoccurrence of fugitive leaks
from valves and pumps.  This program will be more fully described in a paper to
be presented by Weber and Smith at the APCA Meeting in Montreal later this
year.  This program will also develop correlations between screening values
and leak rates for valves and pump seals in chemical process units.

          The screening program being supported by IERL-RTP will screen all
potential fugitive emission sources in some 20 process units except that only
5 to 15 percent of the flanges will be included.  The work is being conducted
by four companies:  Radian, PEDCo, Acurex, and TRW.  The last three contractors
are forwarding their data to Radian for processing and interpretation, and
Radian has the responsibility for the final report.  In this study we are
examining a wide variety of chemicals and attempting to study at least two
process units for each type of chemical.  Currently, screening has been con-
ducted at ethylene, ethylene dichloride, vinyl acetate, vinyl chloride monomer,
methylethyl ketone, phenol/acetone, and formaldehyde units.  These data are not
yet sufficiently reduced to give any estimate of the frequency or of variations
between process units producing the same type of chemical.

          In addition, this program is developing response factors for two
types of hydrocarbon sniffers for a large number of industrial synthetic or-
ganic chemicals.  This effort consists of a laboratory study where the response
of specific gases is examined using two Century OVA and two Bacharach TLV hy-
drocarbon detectors.  The response versus concentration data are being
developed at several points between 100 and 10,000 ppm.  It is the intent of
this study to determine the utility of various types of hydrocarbon sniffers/
portable hydrocarbon monitors in screening for maintenance or regulatory pur-
poses for the wide variety of synthetic/organic chemical manufacturing pro-
cesses.  Once again the response factor data are not complete.  It is, however,
safe to say from a preliminary look at the results that response factor does
vary with concentration and may vary between chemicals by one or more orders
of magnitude.

          This study was scheduled for completion in the summer of 1980 but
has, however, suffered severe delays due to difficulties in accessing the vari-
ous process units.  This was caused by the recent chemical workers strike and
by some reluctance on the part of plant managers to have the screening teams in
their units.  Currently, 12 units have been screened and the remainder of the
screening visits have been scheduled.  We anticipate that the data from this
program will be ready in the Fall of 1980.
                                       153

-------
          Acknowledgment s

          The work described in the refinery assessment portion of this paper
was supported by EPA, IERL, RTF under Contracts 68-02-2147, Exhibit B and
68-02-2665.  The cooperation of the participating refineries and of the Ameri-
can Petroleum Institute is also to be acknowledged.  Finally the support of
Radian's field crews and statistical department is gratefully acknowledged.
The work in Part 2 of this paper is supported under the contract from IERL
RTP 68-02-3171, Task 1.  The authors would also like to acknowledge the support
of those companies who have made available their facilities and of the assis-
tance and advice of EPA, OAQPS.
                                     154

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                    EVALUATION OF FUGITIVE EMISSIONS AT A
                         LARGE WOOD-PRODUCTS PLANT

                                     by

                               Peter D.  Spawn
                           Environmental Engineer

                               GCA  CORPORATION
                           GCA/TECHNOLOGY DIVISION
                           Bedford,  Massachusetts
                                   ABSTRACT
     Under sponsorship of the U.S.  Environmental Protection Agency (EPA),  this
program assessed fugitive particulate emissions at a large particleboard plant.
Major and minor sources of fugitive particulate emissions were identified  in
a pretest survey.  Emissions from major fugitive sources — open doorways in
large material handling buildings — were directly sampled during a 2-week
field program.  Concurrently, ambient TSP data were collected daily at four
sites outside plant boundaries using 24-hour continuous hi-vols and also wind-
actuated units in an upwind/downwind arrangement.  This paper presents the
results of the sampling program and identifies control options applicable  to
the fugitive emissions.
                                ACKNOWLEDGMENT
     This study was funded under EPA Contract No.  68-01-4143, Technical
Service Area 1, Task No. 34.  John R. Busik served as Project Officer for
the overall contract while Norman Edmisten of EPA Region X served as Task
Manager for this particular task.  The author also wishes to thank Tim Curtin
and Barbara Myatt of GCA for their invaluable assistance in conducting the
field program.
                                  DISCLAIMER
     This paper was prepared for the Fourth Symposium on Fugitive Emissions in
New Orleans on 28 May 1980.  The paper is based on the Final Report furnished
to EPA by GCA Corporation, GCA/Technology Division, Bedford, Massachusetts
01730, in fulfillment of Contract No. 68-01-4143, Technical Service Area 1,
Task No. 34.  The opinions, findings, and conclusions expressed are those of
the author and not necessarily those of EPA or of cooperating agencies.
Mention of company or product names is not to be considered as an endorsement
by EPA.
                                      155

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                          PROJECT  BACKGROUND AND  SCOPE

      This  project  assessed  the magnitude  of fugitive particulate emissions at
 a  large Northwest  particleboard plant.  Although  the plant had taken a number
 of steps towards reducing fugitive emissions, violations of ambient air stan-
 dards were still recorded at  the  local TSP monitoring station.  Previous work
 indicated  the  plant was  the primary industrial source responsible for these
 violations, based  on correlations between wind patterns and measured TSP
 levels.  Consequently, the  Oregon Operations Office of EPA Region X requested
 GCA to assess  the  magnitude of fugitive emissions originating from the plant.

      A 2-week  sampling program directly measured particulate emissions from
 major fugitive sources.   These data provided a range of emission rates for a
 variety of plant operational  and ambient  wind conditions.  Ambient air quality
 was monitored  for  TSP at  four sites outside plant boundaries by upwind/downwind
 sampling with  source-oriented hi-vols.  This arrangement was designed to pro-
 vide an indication of the plant's contribution to ambient TSP levels.

      Observation of daily plant operations enabled the identification of
 minor sources  of fugitive emissions such  as conveyor spillage, leaky ductwork
 and wind entrainment of spilled material.  These observations coupled with a
 review of  control  technology  generated a  preliminary assessment of methods for
 reducing fugitive  emissions.

                   DESCRIPTION OF FUGITIVE EMISSION SOURCES

      Particleboard is manufactured by mixing prepared raw wood fibers with
 organic resin  binders and heating the mixture under pressure to form hard
 solid sheets which are then trimmed and sanded to size and shape for sale and
 use.  The  plant facilities  consist of a major building complex housing the
 three production lines and  the storage and loading areas,  and a number of
 smaller buildings  housing raw material storage and preparation operations.

     Fugitive  particulate emissions originate primarily from handling,
 transport  and  storage of  raw materials, which consist of green and dry planer
shavings and plywood trim.  Sources of fugitive emissions  which leave plant
boundaries can be  summarized as:

     •  Major Sources — Material  handling within  four large buildings — the
        truck dump, dry shavings  storage and  two  plywood trim storage build-
        ings - and one open  storage pile (which will  soon  be enclosed).

     •  Minor Sources -  Small  leaks in the air  transport system,  an occasional
        leak in a cyclone, conveyor belt  losses,  an occasional process equip-
        ment upset in the mill and flake  area.

     • Wind entrainment  of  particulate matter  which  originates  from the
        above sources and accumulates  over the  entire plant.
                                      156

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              MAJOR FUGITIVE PARTICULATE SOURCES - OPEN DOORWAYS
                        IN MATERAL HANDLING BUILDINGS

     Figure  1 shows the major fugitive emission sources which were sampled in
this study.  Each source is described below.

     Raw materials — dry and green planer shavings and plywood trim material —
are received from local sawmills in tractor-trailer trucks which are emptied
into two large hoppers within the truck dumper building.  A large hydraulic
lift raises  the entire truck at an angle, emptying it through a rear (truck)
door.  When  prevailing winds are from the west, south or southeast, dust
generated from the dumping operation is carried out the northeast facing
doorway.  A  vibrator located on one of the dumpers to loosen compacted shavings
somewhat increases dust generation.  Green shavings (40 to 60 weight percent
moisture) generate substantially less dust than dry shavings (10 to 11 percent
moisture) or plywood trim.  Under normal operation, about 9 to 10 trucks per
hour are dumped.

     From truck dump hoppers, material travels to storage silos by two belt
conveyor systems, also shown in Figure 1.  When silos are full, incoming
material is  diverted to storage.  Green shavings enter a large outdoor stor-
age pile.  Dry shavings enter conveyors located underneath the dry storage
building roof and fall to storage piles within the building.  Plywood trim
is similarly deposited into one of the two ply trim storage buildings by
overhead conveyors.

     When incoming trucks cannot maintain necessary levels in the storage
silos, silos are refilled with material previously placed in storage.
Bucket loaders "scoop" raw material from storage areas to reentry hoppers
and material travels to appropriate silos by the main belt conveyor system
shown in Figure 1.

     In summary, fugitive emissions from the three material storage/handling
buildings exit to the atmosphere through large open doorways.  The doorway
emissions are generated by the following processes:

     •  Discharge of raw material to storage piles from overhead conveyors.

     •  Bucket-loader scooping of stored material and dumping to conveyor
        hoppers.

     •  Wind reentrainment of particulate during periods of no internal
        building activity, which only occurs with high winds.

                  MINOR FUGITIVE PARTICULATE EMISSION SOURCES

     In addition to the major fugitive sources, i.e., the open doorways, a
number of minor sources were also identified.  External conveyors, although
covered on three sides, lose some material.  Air systems also used to transfer
raw material occasionally leak to some degree.  An occasional upset in  the
mill and flake area generates some fugitive emissions.  All of these minor
sources discharge some particulate directly to the ambient air, and also
create accumulations of dust which are then reentrained by winds.  The  upwind/
downwind sampling program addressed the ambient air impacts of these  (and all
other) plant emissions.

                                     157

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                                                                                                                 W
                                                              NOTE-PNUEMATIC  TRANSFER TO
                                                                   MILL AND FLAKE FROM
                                                                   DRY STORAGE SILOS  AND
                                                                   PLY-TRIM  SILO
                                                                GREEN STORAGE
                                                                    SILO
Ui
a-
                                                                         PLY-TRIM
                                                                         REENTRY
                                                                         HOPPERS
                                                                         (TO SILOS)
                                                                   AAF
                                                                 SCRUBBER
                                                     PLY-TRIM
                                                     STORAGE
                                                                         [DRYER ios|
                                                                         SANDERDUST
                                                               BOILERS
                                                                 AND
                                                                DRYER
                           NO. I  PRODUCTION  LINE
                          GREEN
                           SHAVINGS
                             STORAGE
                                 NO.2 PRODUCTION LINE
                           SILOS FOR
                           PREPARED
                                                                                  II REENTRY
                                                                                  li HOPPERS
                                                                   RAW MATERIAL
                                                                                                 GREEN
                                                                                                 REENTRY
                                                                                                 HOPPER
                                      NO.3 PRODUCTION LINE
                                                                                            METALLIC
                                                                                          REJECT BELT
                              KEY:
BELT CONVEYORS-OUTSIDE BUILDING

BELT CONVEYORS-INSIDE  BUILDING

OPEN DOORWAY
                                                                             NOTE
                                                                                                       TRUCK DUMP
                                                                                                       BUILDING
ARROWS REPRESENT  FUGITIVE SOURCE
EMISSION  POINTS  ADDRESSED IN THIS  STUDY.
                                             Figure 1.   Major Fugitive  Emission Sources.

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               HISTORY OF FUGITIVE EMISSION CONTROL AT THE PLANT

     Handling of raw materials by bucket loaders, conveyors and active storage
piles is inherently a very dusty operation.  When the plant was designed and
constructed in 1960, little attention was given to control of these fugitive
dusts.  All raw material was stored outdoors in piles or open-sided sheds,
belt conveyors were exposed to prevailing winds, plant grounds were unpaved
and the truck dumpers were unenclosed.  Since this time, the plant has made
a number of operational improvements which have served to significantly reduce
the potential for fugitive emissions.  These are summarized in Table 1.

         TABLE 1.  SUMMARY OF MAJOR CONSTRUCTION ACTIVITY AT DURAFLAKE
                   WHICH REDUCED FUGITIVE EMISSIONS
Year                                   Activity
1969    Constructed truck dump building over the two dumpers.
        Purchased used street sweeper.
        Paved parking lot and eastern plant grounds.
        Closed off east end of dry storage building with partition.
1970    Covered roof area between dry hemlock and fir storage sheds.
        Installed truck dump negative air exhaust system and found only
          partially effective.
1972    Enclosed conveyor belts on dry shavings roof.
        Enclosed flight conveyors to dry storage silos.
1973    Paved western plant areas.
        Installed roof over plywood trim storage buildings.
1974    Purchased vacuum truck for cleaning silos and spilled material.
1976    Installed canvas curtain below green shuttle in conveyor discharge to
          reduce wind entrainment.
        Corrected belt: conveyor spillage problems in mill and flake areas.
1977    Installed self-closing personnel doors on dry storage and truck dump
          buildings.
        Installed door to close off eastern opening of the dry storage
          building.

1978    Installed fire hose connections to allow hosing of dusts accumulated
          on roofs of dry and ply trim storage buildings, and mill and flake
          areas.
        Began construction of green shavings pile enclosure building.
        Ordered new street sweeper.
                DESIGN AND OPERATION OF SOURCE SAMPLING TRAINS

     Fugitive emissions from the open doorways were directly measured by
traversing the plume exiting each doorway with a specially designed sampling
train consisting of a calibrated hi-vol motor with filter, and a cyclone pre-
separator to provide a 10 ym particle size cut.  Each doorway was uniformly
traversed in a rectangular grid pattern to obtain an average concentration
of exiting particulates during the hour-long sampling run.  The exit velocity
                                     159

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 of the particulate plume was monitored and recorded  at  each  traverse point.
 With these data,  mass emission rates  could be  calculated based on  the average
 particulate concentration,  the average exit velocity and the doorway cross-
 sectional area.

      Each sampling train consisted of an  inlet nozzle,  a cyclone preseparator
 a standard 8 x 10 inch hi-vol filter,  a hi-vol blower motor,  and auxiliaries
 as shown in Figure 2.   Sampling flow  rate was  controlled by  a variac (rheostat)
 and monitored by  a dial gauge on the  blower exhaust  and also  a manometer across
 the cyclone.   The 4-inch diameter inlet nozzle was designed  to provide sampling
 at a rate approximately equal to typical  doorway  exit velocities so sampling
 would approach isokinetic conditions.   The train  was calibrated by techniques
 similar to those  used for hi-vol ambient  air samplers,  both before and after
 the sampling program.   Design of the  train allowed for  easy  component disas-
 sembly to facilitate sample recovery  from cyclones and  connecting piping by
 acetone washing.

      For each source sampling run,  the  train was  suspended in front of a
 particular doorway from a trolley assembly similar to monorails used for
 stack sampling.   A pulley and rope  arrangement allowed manual positioning of
 the train at  each traverse  (sampling) point.  Monorails were  installed in a
 semipermanent fashion  above two doorways  (the  truck  dump and  western door of
 dry storage)  while remaining doorways were served by  a portable design which
 could be leaned against the doorway.  The  inlet nozzle was always located
 about 12 inches just outside each doorway,  to ensure measurement of actual
 atmospheric emissions,  not  internal building concentrations.

      On a few occasions when winds  were light and/or variable, the doorway
 exit  flow reversed for  brief periods such  that no emission occurred.   In
 these instances,  sampling was  temporarily  halted by stopping  the blower, and
 resumed when  measurable flow was  observed  to exit the doorway.  This  pro-
 cedure  was necessary so sampling  data would be compatible with the technique
 used  to estimate  annual emissions.

            FUGITIVE SOURCE  SAMPLING RESULTS AND EMISSION ESTIMATES

      A  total  of twenty-seven  1-hour sampling runs characterized emissions from
 the four major sources  under  a variety of  plant operational and wind  conditions
 as  shown  in Table  2.  From an assessment of annual wind patterns and  plant
 operation data, annual  emission estimates were developed for each source as
 shown in Table 3.    Since doorway  emissions are nonexistent when winds blow
 into  the doorway,   the several years of wind data available for this site were
 used  to  estimate  the amount of  time emissions would blow out of the doorways.

     On  an annual basis, fugitive particulate emissions from  the four material
handling buildings are estimated at about  50 tons or 15 percent of  process
 stack emissions.  However, GCA feels the sampling data are  biased low due to
 the wet weather and light winds encountered during the study.  The  source
 sampling found that peak emission rates from these buildings could  easily
amount  to 40 Ib/hr or more on weekends or nights with moderately southwesterly
and westerly winds, compared to process stack emissions of  100 Ib/hr.
                                     160

-------
   MONORAIL  INSTALLED
                                               o rr
     ABOVE  DOORWAY
      8xlG inch HI-VOL
      FILTER and  HOLDER(S"
                FLOW (\
                GAUGE
                                                  \
                                                     /TROLLEY/ROPE ARRANGEMENT TO ALLOW
                                                     COMPLETE  HORIZONTAL  AND  VERTICAL
                                                     POSITIONING  FOR TRAVERSE
                                                                   PRESSURE  TAPS TO
                                                                       MANOMETER
                                                      	'  >	 INLET  NOZZLE
                                                           CYCLONE  DROP-OUT
                                                               BOTTLE
Figure 2.   Front view of source  sampler  constructed for Duraflake sampling program.

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                        TABLE 2,   SUMMARY 07 SOURCE SAMPLING DATA FOR MAJOR FUGITIVE SOURCES
N.
Source
Truck dump

Dry storage
building
west door
Dry storage
building
east door
Ply trim
building*


Ply trim
hopper
Roof monitors
production
line 3
Number /
of
samples
5
1
2
2
1
5
1

4
1
1

4

13


Average
<10V
0.3
0.9
0.1
0.1
0.8
0.5
1.0

0.1
0.3
0.2

0.1




emissions Ib/hr
>10u
3.7
12.0
1.9
4.7
13.0
12.0
37.0

7.0
25,0
8.1

8,7

0.1


Internal activity
Normal operation, light winds
One truck, very dusty material, light wind
No activity; front door closed, light wind
Light activity; front door open, light wind
Continuous conveyor discharge, front door open, light wind
Normal weekend payloader operation, light to moderate wind
Heavy payloader operation near door; moderate winds

Peak emissions during conveyor discharge, light winds
One dusty conveyor discharge, moderate winds
Average emission during payloader removal of stored
material
Dust from payloader discharge to reentry hopper, time
averaged emission
Survey measurements of roof monitor emissions during
normal operation

     *Reported values  for one of two doors  in building emissions normally escaped only  through one door.




     Data  for particles less than about  25 ym.

-------
         TABLE  3.   ANNUAL EMISSION RATES FOR MAJOR FUGITIVE SOURCES

                            Estimated  Percent °f  A       T0    T
                                  ^    year with   Average TSP  Net annual
            Source                  .       dust      emission     emission
                            operating          .       ,,. „ ,     ,     .   N
                              r,     °  generating     (lb/hr)     (tons/yr)
                                          wind

   Truck  dump                   2,850        51           3.7          2.7

   Dry  storage-west door
     normal  daily activity      6,260        54           1.9          3.2
     payloader  operation        4,000        54         12.0         13.0

   Dry  storage-east door
     normal  daily activity        313        46           1.9          0.14
     payloader  operation        4,000        46         12.0         11.0

   Ply  trim  buildings
     conveyor discharge           830        53           7.1          1.6
     payloader  activity         4,000        75           8.1         12.0

   Reentry hopper at ply trim   4,000        53           8.7          9.3

     TOTAL ANNUAL DOORWAY
EMISSIONS
Inventoried process
(stack emissions)
53
8,100 100 96.2 391
     Particle size data collected during all sample runs showed that less than
5 weight percent of emissions were smaller than 10 vim aerodynamic diameter.
However, this does not necessarily indicate that most particles are heavy and
soon settle to the ground.  Observations during sampling found most emitted
particles were entrained in prevailing winds and significant fallout on plant
grounds did not occur.

                   UPWIND/DOWNWIND AMBIENT SAMPLING APPROACH

     To evaluate the impact of particulate emissions from the plant on ambient
air quality, upwind/downwind sampling was conducted concurrently with the
source sampling programs.  Based on an analysis of historical wind data, four
ambient sampling sites were selected, two upwind and two downwind of the plant.

     To the north, one hi-vol operated continuously for 24-hour periods while
a colocated, wind-actuated hi-vol only operated when winds were from the plant
sector.  An additional single hi-vol, also located to the north, operated
continuously for 24-hour periods.

     A similar arrangement of hi-vols was operated to the south of the plant.
Since winds tended to blow north-south, or south-north, these hi-vol stations
were designed to cope with anticipated wind patterns.

     Hi-vols operated daily for 12 days with filter changes conducted at mid-
night of each day.  An electric clock wired into the wind controls recorded the
actual time the wind-actuated hi-vols operated.  Wind direction and wind speed
were continuously monitored and recorded on a strip chart unit.

                                      163

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                         AMBIENT TSP  MONITORING RESULTS

      The ambient monitoring program  collected  a total of  forty 24-hour TSP
 samples at six hi-vols to  the north  and  south  of the plant  for 12 continuous
 days.   The ambient  data for each site is summarized in  Table  4.

      Upwind/downwind sampling showed substantial increase in  ambient TSP when
 winds  originated from a sector including the plant boundaries, but excluding
 adjacent industrial facilities.   Based on data from this  monitoring program,
 particulate emissions from the plant apparently increased ambient TSP roughly
 two to four times above measured background levels, as  shown  in Table 5.

     Weather conditions during the sampling program did not appear representa-
 tive of those which would  produce maximum fugitive emissions  from the plant.
 Steady rainfall was experienced over roughly one-half of  the  period and winds
 were generally calm or light.   Further,  TSP measured by GCA at the permanent
 site to the north was significantly  lower than that recorded  by the state
 agency over past years.  For  these reasons, TSP levels measured at ambient
 sites  and also from fugitive  (doorway) sources at the plant are considered to
 represent a lower limit to emission  potential,  not a maximum.

                         CONTROL TECHNOLOGY ASSESSMENT

      In general,  control options for fugitive  particulate emissions fell into
 two categories:

     •  Complete control by capital-intensive  techniques; i.e., evacuating
         all buildings to baghouses,  and  redesigning raw material handling
         processes.

     •  A lesser degree of control,  achieved by minor structural modifica-
         tions,  operational changes,  and  a  dramatic increase in attention to
         plant  housekeeping and cleanliness.

 Options  for control  of each type  of  fugitive emission are summarized in Table 6
 and  discussed  briefly below.

     Complete  control of the open doorways can only be accomplished by evacua-
 tion and  diversion  of the  emission flow  to a baghouse.   The buildings cannot be
 sealed because of the  potential  for  explosions and also worker safety/health
 concerns.   Although  technically  feasible  (the metallurgical industry often uses
 complete  building evacuation to  control plants containing a number of diffuse
 emission  sources),  the  capital costs per building would be on the order of one-
half million dollars.  This cost for complete control must be weighed against
 the potential emission reduction.  Fugitive emissions from these  buildings
account for an estimated 15 percent of process stack emissions on an annual
basis and a maximum of 40 percent of stack emissions on a peak daily basis.

     As an alternative to the baghouse option,  emissions from these buildings
could be  reduced, possibly by as much as 50 percent,  by implementing a  number
of structural and operational modifications listed in Table 6; i.e.,  reducing
doorway size, constructing enclosure type sheds over reentry hoppers,  install-
ing conveyor discharge downspouts, and retraining plant operators.
                                      164

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                       TABLE 4.   SUMMARY OF AMBIENT TSP SAMPLING CONDUCTED IN SEPTEMBER 1978,  yg/m3
U'
Date satellite
9/7

9/8

9/9

9/10


9/11

9/12

9/13

9/14

9/15


9/16
9/17

9/18
Mean
- THU

- FRI

- SAT

- SUN


- MON

- TUE

- WED

- THU

- FRI


- SAT
- SUN

- MON

Maximum
28

77

70

137


179

99

73

65

122


69
58

120
91
179
Mortuary Mortuary
24-hour W. D.
-

99

95

162


91

41

58

32

43


31
48

73
70
162
-

216

233

269


207

-

100

60

180
(1-
hour)
-
175

302
194
269
South
Main
24-hour
38

46

25

45


61

86

57

44

137


143
91

66
70
143
South
Main South
W. D. satellite Wind and weather
-

-

-

160


-

152

73

63

161


192
80

116
192
125
- Light south wind,
clear until noon,
rain until 6 a.m.
Light south wind,
rain all day
70 Light south wind,
rain
- Light south-se wind,
rain in mornings,
clear thereafter
37 Light south wind,
dry by evening
- Light northerly
winds, variable
40 Light variable wind,
no rain
Light variable wind,
no rain
78 Light north wind, dry


Light north wind, dry
- Moderate south wind,
dry - a.m., rain - p.m.
57 Light south wind, dry
56
78

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             TABLE 5.  AVERAGE MEASURED TSP BY WIND DIRECTION,  ug/m3
                             North       North       South       South
                  North      Main        wind        Main        wind         South
                satellite   24-hour  directional   24-hour  directional   satellite
Average of 7      95
  days  with
  south wind

Average of 3      97
  days  with
  north wind
        96
        38
200
53
           122
                                                         55
            168
Note:   Winds not  always constant in direction.
          TABLE 6.   SUMMARY  OF CONTROL  OPTIONS APPLICABLE TO DURAFLAKE
         Emission
          source
                Control
                option
                       Comments
      Major  sources -
        open doorways
     Minor sources
     General dust
       accumulation
Evacuation to baghouse

Structural modification
  - doorway size reduction to
      reduce emission flow rate
  - enclosure sheds over reentry
      hoppers to minimize dust
      entrainment
  - conveyor downspouts to mini-
      mize free  fall distance

Operational changes
  - retraining of bucket loader
      operators  to operate equipment
      more carefully
  - more diligent closure of
      existing doors

Complete enclosure of belt conveyors

Installing more  effective belt wipers

More effective control of leaky
  ductwork, cyclones, etc.

Vacuum sweeper - daily use
Hosing of roofs  and ductwork - daily

More careful operation of
  vacuum truck

General reduction in dust
  generating activity
                   Capital intensive
                   Very efficient

                   Relatively inexpensive
                   Less effective
                     than baghouse
                   Requires cleaning
                  New sweeper ordered
                  Hose connections
                    currently installed
                                        166

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     Improved control of minor point-type sources of fugitive emissions can  be
achieved primarily by more effective conveyor belt enclosures to  eliminate
spillage, use of more effective belt wipers,  and more attention to  repair of
leaky duct work, cyclones, and other minor sources.

     A major problem at the plant is the substantial accumulation of  dust over
plant surfaces, which contributes to windblown fugitive emissions.  The solu-
tion here is simply more attention to housekeeping details.   A three-wheel,
brush-type street sweeper is reportedly on order and should  be used daily on
all plant grounds.  Hosing of rooftops and other plant surfaces that  collect
dust should be conducted daily since GCA's observations indicated enough
material can accumulate in 1 day to constitute a windblown dust problem.  The
plant currently operates a vacuum truck for cleaning major spills and/or
storage silos and hoppers, and more frequent  use of this equipment  should be
encouraged.

                        CONCLUSIONS AND RECOMMENDATIONS

     Based on GCA's evaluation of fugitive emissions during  the 2-week sampling
program, the following comments and recommendations are offered.

     •  Major fugitive emission sources contribute about 50  tons  per  year
        of TSP annually, or about 15 percent  of inventoried  stack TSP.

     •  Violations of ambient TSP standards were recorded outside of
        plant property.

     •  Upwind/downwind hi-vol sampling showed increased ambient  TSP  when
        winds were from the plant sector.

     •  Based on the 2 weeks of hi-vol data,  all plant emissions  increase
        ambient TSP by a factor of 2 to 4 above background levels.

     •  All sampling data are considered to represent minimum emission
        levels since the sampling period experienced low wind speeds  and
        wet weather.

     •  State-of-the-art control of fugitives involves capital-intensive
        measures — complete building evacuation and/or process redesign.

     •  A moderate level of control can be achieved by minor structural
        modification and minor operational change.

     •  A dramatic increase in overall housekeeping is essential  to
        reduce windblow fugitive dusts.

     •  Although only 5 percent of the fugitive emission particulate  was
        measured at less than 10 ym, visual observations indicated  that
        much of the TSP became entrained in ambient wind currents and
        did not descend on plant grounds.
                                      167

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              A  Method for Measuring Fugitive  Emissions
                      From Cast House Operations

                           James H.  Geiger
                      Betz«Converse»Murdoch»Inc.
                               Abstract

    An attempt to measure fugitive emissions from blast furnace cast
house operations presented a variety of problems.  A method was
developed to determine a mass emission rate.  The method utilizes
high volume samplers placed in a multipoint array where temperature
and velocity measurements also are made.  The reasoning behind  the
method is discussed, and the method is compared to other "state of
the art" procedures for measuring fugitive emissions.  Certain
factors which affect the emission measurements are discussed.
Results indicate that the method is reasonably accurate for
determining mass emission rates from cast house operations.

    This paper is a synopsis of several measurement programs and,
although the basic methodology was the same, the type of equipment
used varied for each program.   The method, currently being  used in
an ongoing program to quantify emissions from cast houses,  is
continually undergoing refinement.
                                 160

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    The emissions generated by a blast furnace during casting
originate from relatively small point, line and area sources (tap
hole, runners, hot metal cars); they expand quickly to the
dimensions of the cast house and exit by a number of routes.
Emissions from the tap hole are caused by the cooling of the hot
metal as it exits the furnace and encounters the atmosphere.  More
emissions are created by a violent cast with a lot of hot metal
turbulence than are generated by a smooth, controlled cast.   Oxygen
lancing of the tap hole at the beginning of a cast and the
enlargement of the tap hole by erosion during casting also
contribute to increased emissions.

    The generation of emissions from the iron runners, iron trough
and slag runners is apparently a function of the surface area of
metal exposed to the atmosphere and the metal temperature.  As the
metal cools, carbon emerges from the hot metal solution as "kish", a
form of graphitic carbon that  is light, flaky and readily
air-borne.  The trough and runners are lined with clay and coke
breeze which must be thoroughly dry prior to casting.  Any residual
moisture reacts violently with the molten metal, resulting in
greater emissions.

    The hot metal cast from a  blast furnace is transported  to
further processing facilities  via hot metal cars (i.e., ladle cars,
torpedo cars).  The hot metal  cars are filled by the  iron runner
spouts.  If the hot metal cars are too cool, if a "skull" has formed
over the car opening, or if the hot metal splashes onto the inside
of the car opening, the hot metal cools very rapidly, and the
emissions from the cars can become extremely dense.

    Because fugitive emissions are not confined, they are inherently
difficult to quantify.  Three  basic strategiesl»2,3 nave been
developed for the measurement  of fugitive emissions:  the roof
monitor, the quasi-stack, and  the upwind-downwind methods.  All
three methods, or variations thereof, have  been used  in an  attempt
to quantify blast furnace cast house emissions^.

    The roof monitor measurement technique  assesses emissions
exiting through monitors, doors, windows, ventilators or other
openings.  Usually high volume samplers^  are  utilized to measure
the  concentration of particulate passing through the  opening.  A
velocity is determined  and  a mass emission  rate  is  calculated  for
each opening.  The numerous openings present  in cast  houses,  and  the
physical problems associated  with sampling  at  those openings,
precludes the  use of the  roof  monitor sampling method.
                                  169

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     The quasi-stack sampling method employs  a temporary hood  which
 is exhausted by a fan to a temporary stack.   The  hood  and exhaust
 system are designed to capture most (theoretically all)  of  the
 emissions  from the process being investigated.  Then,  the mass
 emission rate is measured by standard stack  sampling techniques.
 The quasi-stack sampling method is  impractical  for cast  house
 testing because it interferes with  production equipment  and
 personnel.   Also, the design for the temporary  hoods would  have to
 meet strict  criteria, including the ability  to  withstand high
 temperatures.

     The third method, upwind-downwind sampling, as  well  as  a  fourth
 method, measurement in the plume, seemed  the  most  promising methods
 to use. The plume measurement method was  developed by Jacko? for
 measuring  coke oven pushing operations.   The  method used a  high
 volume sampling device suspended from a boom  into  the  plume.  The
 boom also  held velocity and temperature measuring  instruments.  The
 push was filmed with a 16 mm movie  camera.   The resulting film was
 then projected onto a screen and measurements were made  to determine
 the cross  sectional  area of the plume.  The film was also used to
 determine  when the samplers actually intercepted the plume so that
 an accurate  sampling time could be  determined.

     Observations of a number of casts indicated that neither  the
 plume measurement technique nor the upwind-down wind method would
 work.   The numerous  points  of exit  for emissions from  a cast  house
 result in  a  plume whose boundaries  are not as well  defined as those
 from a coke  oven, making it difficult to  determine the plume
 cross-sectional  area.   Also,  interferences from surrounding sources
 would have had a substantial  impact  on either sampling method.

     The sampling methodology  that eventually  evolved was one  that
 had been dismissed earlier  as  being  too difficult to implement.   The
method could be  described  as  an in-situ stack method because  the
 entire cast  house was  considered to  be the stack.   The
 cross-sectional  area  of  the  cast house was divided into sub-areas
 and  each sub-area  was  sampled  simultaneously.  Samples  were taken
with  standard  high  volume  samplers  with constant flow controllers.
The  samplers were placed  on a  scaffolding which was erected on the
 roof  girders just  above  the crane.

    The philosophy behind such  a sampling arrangement was simple.
Observations indicated  that emissions exited the cast house via five
 routes: hot metal car  (ground)  level; cast house floor  doors;
windows; roof monitor;  and  around the furnace shell at  roof level.
The emissions from  each  route  were present in varying degrees during
each  cast,  but the bulk of the  emissions appeared  to be exiting  via
the higher  exit points  (windows, monitor,  roof top).  By sampling  at
the roof girder  level,  (approximately window height),  the bulk of
the emissions would be intercepted.
                                 170

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    One objective of the first test  program was  to  determine
emission factors for each source within the cast house (i.e.,  tap
hole, runners,  hot metal cars).   Consequently, the  scaffolding and
samplers were placed to maximize plume interception from  the
individual sources while maintaining sufficient  coverage  of the
entire cast house.  The spatial  limitations of the  cast house  girder
system determined the exact placement of the scaffolding.

    To develop emission rates, plume velocity and cross-sectional
area must be determined.  Conduction and convection transfer
significant quantities of heat to the surrounding air creating a
thermal draft which causes a rising  air current. As the  heated air
stream rises from a hot surface, it  mixes turbulently with the
surrounding air.  The higher the air column rises the larger  and
more diluted with ambient air it becomes.

    Equations have been developed that describe  the diameter  of a
hot rising jet at any height above a hypothetical point  source
located a distance, z, below the actual hot surf ace. 8  The rising
air column expands approximately according to equations  1 and 2 as
indicated in Figure 1.  A cross-sectional area at the height  of the
samplers was calculated from equations 1 and 2 for  each  of the hot
sources in question (iron trough, runners, hot metal cars).  The
resulting areas are indicated in Figure 2 by the shaded  areas.

    To complete the flow calculations, a velocity must be determined
and applied to the previously computed areas. The velocities of the
emissions were primarily determined  by photogrammetric methods.  A
movie camera with a precisely controlled shutter speed was used to
photograph various portions of each  cast.  The developed  film was
projected onto a grid.  As the film was advanced a single frame at a
time, an  identifiable portion of a particular plume was  followed on
the grid.  By using simple geometry, the grid was calibrated  to the
known size of objects projected onto the grid and distances between
reference points were established.  The velocity of the plume was
calculated by counting the number of frames  it took the plume to
travel the distance between reference points and multiplying  by the
framing speed of the camera.  This procedure was followed a number
of times for each plume  to arrive at an average plume velocity.  For
emission  points, such as over the iron runners,  which did not have
readily identifiable plume attributes, a different procedure was
used.  Neutrally bouyant helium filled balloons were released and
tracked as they were projected onto the grid as described above.
The vertical transport  of the balloons was  timed for comparison with
the calculated  velocities.  In  addition, a  hot wire anemometer was
used  to determine velocities  outside the areas  of  the plumes.
                                 171

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where:
               z
               Or
2D.1.138
0.5
(1)
(2)
                         the  diameter  of  the  hot column  of  air
                         at the level  in  question, ft

                         the  diameter  of  the  hot source,  ft

                         the  distance  from the  hot source to the
                         plane of Dc,  ft

                         the  distance  from the  hot source to the
                         hypothetical  point source, ft.
              HYPOTHETICAL

              POINT SOURCE
                         Figure  1'

            THEORETICAL EXPANSION OF AIR COLUMN
                    DUE TO HOT SOURCE
                           172

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                                     SLAG SPOUT W.T
 .
--
                                                                                                 o
              5%H IRON TROUGH PROJECTED AREA


              Z~M RUNNER PROJECTED AREA


              MM TREADWELL PROJECTED AREA


               •   AIR SAMPLING  LOCATIONS
FIGURE  NO.  2
                                                                      SAMPLING  NETWORK  SCHEMATIC

-------
    Once  velocities  and  areas  were  determined,  the flows at  a given
 sample  location  were  calculated.  The  gas flow  at a  given sampler
 was calculated as  a  time weighted average of  each of the velocities
 and sub-areas  as calculated  above.   For  example  (referring to Figure
 2), the determinations of  flow within  the"domain" of sample  point
 number  5  is  composed  of  the  flow from  the non-plume  area, the flow
 from  a  portion of  the runner when filled with hot metal, and the
 flow  from a  portion  of the plume from  hot metal  car  number 3 during
 the time  that  hot  metal  is going into  that car.  This relationship
 can be  expressed mathematically as  follows:

             n
             £    V, Af t,

 Qa  =        i'°l	                                   (3)
where:

    A-j    =     the  itn  area, ft2
    T     -     total  time of test, min.
    t-j    =     the  time that the  ith  area was affected by the i'th
               velocity, min.
    Qa    =     the  average flow at the  sample point  (ventilating
               rate), ft^/min
    y.j    =     the  i™  velocity, ft/mi n

    Note:      n  is a variable depending upon the specific point.
               Ai = f(Dc)

    Twelve  standard  high volume  samplers were placed on the
scaffolding for  the  parti cul ate measurement as indicated in Figure
2.  All  twelve  samplers were activated simultaneously by a common
switch at floor  level.  The samplers were started when tap hole
drilling  was started.   Since there are significant  emissions after
the furnace is plugged, the samplers were not turned off until five
minutes after  the mud  gun was placed in the tap hole.  Then, the
filters were changed and the samplers  were readied for the next test.

    During the first test program, the emissions were observed to
have a pronounced horizontal movement  toward the furnace which acted
as a natural draft chimney.  This unanticipated movement of the
emissions prevented the determination of emission factors for each
individual source and  caused a reassessment of the  sampler
placement.  In subsequent test programs, normal stack testing
methodology has  been adopted; i.e.,  an attempt has  been made to
sample equal areas with the samplers placed at the  center of each
area and  to include the areas at the front of the cast house on
either side of the furnace.  An example of such an  arrangement is
shown in Figure  3.  Final placement  of the samplers is, however,
                                174

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--
_-



I||M|| '

n
T

CO


L,^ — 	

12
•

11



_«;
T
A
L

U
A



___— ^_ —

10

9
•




- L
.
	 !

I \
i
I
^

7
i

^^*
1 1
^•M

I
                                                        -20-
                   • AIR SAMPLING LOCATIONS


                   A LOCATION OF NOT METAL POURING STATIONS
                                                                                 Figure 3
SAMPLING NETWORK SCHEMATIC

-------
 still  dependent  upon  the  spatial  limitations  of  the  cast house
 girder system.

    One other major revision,  the elimination of velocity
 determination by photogrammetry,  has  been made to the basic test
 method used  in  subsequent  programs.   Instead, hot wire  anemometers
 and thermocouples  were  placed  at  each  sampler location.  The
 thermocouple signals  were  fed  to  a multipoint recorder.  In an
 attempt to maximize data  acquisition  yet minimize cost, the hot wire
 anemometer outputs were fed  to a  multiplexer  and then to single
 channel strip chart recorders.  Velocities  at four different sample
 locations were recorded simultaneously.

    Standard high  volume  samplers  were chosen primarily for their
 ease of operation.  Additionally,  the  upright design prevented loss
 of sample, and the cover  prevented sample contamination from
 fallout.  The design  also  provided some size  selectivity which
 excluded particles that would  probably settle out within the cast
 house.   The  samplers  were  equipped with constant flow controllers
 which  simplified data reduction and enhanced the data reliability.

    Tests during each cast also included particle size data
 collection using a five stage  cascade collection  device attached to
 one of  the high  volume  samplers.   The cascade device was moved from
 sampler to sampler throughout  the program.  Because  only one cascade
 device  was used, no simultaneous  particle size data  was collected.
 Since  it is  unknown whether  the particle size data variability was
 point-to-point variability or  test-to-test  variability, the data was
 treated as if it were from the same population.  Averages indicate
 that approximately 85%  of  the  particles are less  than the 7.2 micron
 cut-off size of  the first  stage.   Because the high volume sampler is
 fairly  effective up to  about 100 microns, the samples were probably
 indicative of the  emissions  actually leaving the  cast house.

    Testing  was  also  conducted between casts so  that background data
 could be obtained.  The data collected for the periods between casts
 was considered as  "upwind" data and was subtracted from the cast or
 "downwind" data  in subsequent analyses.  This data treatment was
meant to account for  the material  remaining in the cast house after
 the cast was completed  and the driving force (heat)  was removed.
 The residence time of this suspended material could not be accounted
for and the  extent to which  it contributed to the cast test results
was unknown.  Therefore, it  was subtracted from  them.

    In  one of the  test  programs, observed interference of
 particulate  matter from an adjacent process necessitated the
 acquisition  of the background data.  Because the  generation of the
 interfering  particulate matter was not constant,  the impact on the
 results of the individual  cast tests is unknown,  but it is  believed
that the average values were reliable estimates.
                                 176

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    During normal  casting operations, the slag which floats on top
of the hot metal  is skinmed off.   It is shunted via runners to a
slag pit adjacent  to the cast house or into slag pots which then are
transported to a remote disposal  area.  In some cast house
operations, the cinder notch is opened and slag is flushed from the
furnace without casting any hot metal.  This flushing operation is
performed just prior to a cast.  Since this operation results in
noticeable emissions, testing was performed during the flushes and
the results were added to those obtained from cast tests.

    One area of concern not addressed during any of the sampling
programs was any effect on the measurements, caused by local
meteorology.  Since cast houses are fairly open, wind direction and
velocity could modify pollutant trajectories.  Also, the difference
between summer and winter temperatures can cause variations in
emissions.  During one test program, what appeared to be a
convection cell was established within the cast house itself.  To
what extent this cell would impact on the measurements is unknown as
is its cause and relationship to the local meteorology.

    Although some areas need further investigation and a few
questions need to be answered, the prelimi nary results of the
in-situ stack method are encouraging.  To date, the method has been
used to generate mass emission rate data for a process for which
little reliable data previously existed.  The method uses reliable,
readily available equipment and is suitable in a wide variety of
applications where conventional sampling methods would be difficult
to implement.  With further refinements, the method is capable of
generating more detailed results in a cost-effective manor.
                                 177

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References

1)  Technical Manual for the Measurement of Fugitive Emissions:
    Roof Monitor Sampling Method for Industrial Fugitive Emissions.
    Industrial Environmental Research Laboratory, U.S.  Environmental
    Protection Agency, Research Triangle Park, North Carolina.   May
    1976.  Publication No. EPA-600/2-76-089b.

2)  Technical Manual for the Measurement of Fugitive Emissions:
    Quasi-Stack Sampling Method for Industrial Fugitive Emissions.
    Industrial Environmental Research Laboratory, U.S.  Environmental
    Protection Agency, Research Triangle Park, North Carolina.   May
    1976.  Publication No. EPA-600/2-76-089c.

3)  Technical Manual for the Measurement of Fugitive Emissions:
    Upwind-Downwind Sampling Method for Industrial Fugitive
    Emissions!Industrial Environmental Research Laboratory, U.S.
    Environmental Protection Agency, Research Triangle  Park, North
    Carolina.  March 1977.  Publication No. EPA-600/2-76-089a.

4)  Blast Furnace Cast House Emission Control Technology
    Assessment!Industrial Environmental Research Laboratory, U.S.
    Environmental Protection Agency, Research Triangle  Park, North
    Carolina.  November 1977.  Publication No. EPA-600/2-77-231

5)  Private Cormunications

6)  T.E. Kreichelt and T.G. Keller, "Roof Monitor Emissions: Test
    Methodology," J. Air Pollution Control Association.  22:8. 641.
    (Aug. 72)

7)  R.B. Jacko, D.W. Neuendorf, and J.R. Blandford, "The By-Product
    Coke Oven Pushing Operation:   Total and Trace Metal  Particulate
    Emissions," Presented at APCA Annual Meeting, Portland, Oregon,
    1976.

8)  Air Pollution Engineering Manual. U.S. Department of Health,
    Education and Welfare.  Public Health Service Publication No.
    999-AP-40.
                                173 •

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                                  STEEL MILL
          PARTICULATE CHARACTERIZATION AND SOURCE/RECEPTOR ANALYSIS

                     U.S.  Steel Corporation Geneva Plant
                              Philip A.  Russell
                        Materials Analysis Laboratory
                   Metallurgy and Materials Science Division
                          Denver Research Institute
                             University of Denver
                           Denver, Colorado  80208
                                   ABSTRACT

     This study (1) characterized particulate emissions from fugitive sources
within a steel mill to determine their potential to be utilized as relatively
unique environmental indicators and (2) determined their relative presence
and quantity in the ambient environment within a region near the plant.   Analy-
ses were made using scanning electron microscopy/energy dispersive X-ray
spectroscopy (SEM/EDS) and transmission electron microscopy/selected area elec-
tron diffraction (TEM/SAED).  Distinct species of particulates were identified
which could be useful in source/receptor analyses.  These include carbon
particles produced during coking, open hearth and blast furnace operations;
iron spheres produced during blast furnace and open hearth operations; angu-
lar Fe and Fe-rich particulates produced during sintering plant operation;
potassium-sulfur rich particle type produced only in the slag flush and slag
tap sections of the blast furnace; and encapsulated iron particles produced by
door leaks after slag charging.  Examination of ambient samples further demon-
strated that the carbonaceous particles and iron spheres produced by the steel
mill were the best environmental indicators of the steel mill impact.  Angular
Fe and Fe-rich particulates were also useful indicators in the vicinity of the
steel mill itself.
                                INTRODUCTION

     It has been hypothesized that observed light scattering problems and high
TSP levels in the Prove, Utah area are significantly affected by particulate
emissions from the U.S. Steel Corporation (USSC), Geneva Plant, located north
of Provo, Utah.  The Materials Analysis Laboratory, Denver Research Institute,
performed a particulate characterization of (1) source emissions from the USSC
Geneva Plant, located north of Provo, Utah, and (2) ambient samples collected
within the region to determine the feasibility of obtaining fugitive emission
source/receptor information using microinventory analyses.  Samples submitted
for analysis were collected on 0.2 and 0.4 pm Nuclepore polycarbonate thin
membrane filters in ^ 7-10 LPM low volume air filter systems.  Analyses were
designed to provide definitive information on the composition and concentration
of particulate species distributed on nuclepore substrates by using scanning
(SEM) and transmission  (TEM) electron microscopy, energy dispersive X-ray
spectroscopy and selected area electron diffraction.  The study was conducted


                                     179

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 in two phases:  (1) the characterization of fugitive particulate emissions  from
 sources within the steel plant to determine their potential to be utilized  as
 relatively unique environmental indicators specific to the Geneva steel plant-
 and (2) determine the presence and quantity of such particulates in the ambient
 environment in the vicinity of the plant.   Because the project was terminated
 for unspecified reasons prior to its completion,  much of  the material  presented
 in this paper was derived independently by Denver Research Institute.   At this
 date the exact locations of the ambient sampling  sites have not been made
 available to the author.
                             METHODS  AND MATERIALS

      All samples were collected by the  Environmental  Protection Agency, Nation-
 al Enforcement  Investigation Center, Denver,  Colorado, during  the fall of  1977
 Particulates on thin membrane polycarbonate filters were examined "in situ" by*
 coating excised portions  of  each filter with    20.0 nm of  carbon by vacuum
 evaporation to  make them  conductive.  Each sample was quickly  examined for
 even particle distribution and then  random portions of the filter were photo-
 graphed at  magnifications adequate to examine particles of interest.  These
 particulates were simultaneously subjected to individual qualitative X-ray
 analysis; comments were recorded directly on  photographs or separate notation
 sheets.  The number of particulates  examined  on any photograph ranged from
 approximately 10 to 100;  numerous photos were analyzed where practical to  pro~
 vide adequate sample sizes.   X-ray emission spectra of typical and unusual
 particulate species were  recorded for future reference.

      Estimates  of mass loadings  were  derived from measured particle size and
 the  area observed.   It was assumed for  calculation purposes that all particles
 were spheres with a diameter  estimated  by averaging a particle's longest axis
 length  and  its  most representative width at right angles to this axis.  Specif-
 ic gravity  was  assumed to be  2.0 for  carbon, 2.4 for "CaS", 5.2 for Fe or Fe-
 rich, and 2.6 for "KS" particulates.   Thus by using (1) the assumed specific
 gravity, (2)  the  number of particles  located in a specific area(s) and (3) the
 estimated individual average  particle volume it was possible to estimate mass
 loading in  gm cm"2.

     Only high magnification  photographs (5,OOOX and 10,OOOX) were used to
 analyze ambient samples, which restricted analyses to relatively small parti-
 cles  0\> < 5.0 urn) for  the purposes of this study.  For particles less than l.Q
 Vim the procedure  was to measure all of  the particles in 20mm x 20mm grid placed
 on a series of randomly selected areas  of a photograph.   Average particle size
was calculated and  the total number of particles of a group in the area are
 entered into  the  equation (#  of particles/cm^)  (avg.  particle vol.-cm )
 (density-gm/cnr)  = gm  cm.   For larger or less prevalent particles,  a whole
photograph or number of photographs were used instead of a portion of a filter

     Samples were also examined by transmission electron microscopy to provide
higher resolution of very fine structural detail, interior particulate morph-
ology and crystallinity (by electron  diffraction).   The  process of  membrane
filter dissolution and  subsequent examination  are detailed in Ruud  et  al.  (1976)
                                     180

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                                   RESULTS

A.  Source Samples

    1.  Coking Process

        a)  Door Emissions

            Particulates observed on three samples were very sparse.. The par-
            ticulates noted were spheres of carbon ranging from 0.5-2.5 ym in
            diameter.  In one sample mineral particles approximately 2-5 ym in
            effective diameter were also observed.

        b)  Pushing

            Emission observed on two samples contained virtually no particles.

        c)  Process Charging

            No large particles on this sample.  Some small carbon spheres 0.27
            ± 0.11 ym in average diameter in low concentration 8.64 x 10" cm"2
            were present.  This is approximately 1.78 x 10~7 gm cm"2 assuming
            a specific gravity of 2.0.

        d)  Ambient Conditions Topside

            Two samples were examined.

             i)  The first sample contained two morphologically different spe-
                 cies of carbon particles (Figs. 1 and 2).  The first were
                 larger spheres 1.18 ± 0.41 ym in diameter in a concentration
                 of 9.43 x 105 cm~2 which estimated to be 1.62 x 10~6 gm cm"2.
                 The second group of particles were smaller but more numerous
                 with an average diameter of 0.15 ± 0.04 ym in a concentration
                 of 1.5 x 10^ cm2 with an estimated mass concentration of 5.30
                 x 10~6 gm cm"2.  These smaller particles were often observed
                 to be agglomerated.  Both species contained trace amounts of
                 Al, Si, S and Cr.  The larger spheres were observed to usually
                 be hollow when examined by the TEM (Fig. 3).

            ii)  Sample C-9-18 contained larger particles similar to those
                 observed in C-13-21; however, the morphology of some of these
                 particles was distorted in shape such as to suggest that they
                 had been fluid at one time (Fig. 4).

        e)  Cap Leaks

            Few particalates were observed on the sample examined.

    2.  Open Hearth

        a)  Door Leaks After Slag Charge

            Mineral particulates  (l-10ym) were observed in moderate

                                      181

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     Fig.  1.   SEM micrograph of coke particles,
              10.000X.
CO
to
                           0.1pm

              TEM micrograph of two
              species of coke particles
                                                                                  TEM micrograph  of coke
                                                                                  particles,  lO.OOOX.
Fig. 4.  TEM micrograph of "hollow"
         particles of coke, 2.000X.

-------
    concentrations,  they contained various amounts of Si, Fe and Ca.
    The smaller particles (Fig.  5) contained Fe and carbon particles.
    The Fe particles have an "encapsulated" appearance with a size of
    0.40 ± 0.17 ym,  concentration of 1.26 x 10  cm   and mass concen-
    tration of 2.20  x 10~  cm   assuming a specific gravity of 5.2
    The carbon particles were somewhat spherical or plate-like and had
    a size of 0.28 ± 10 ym, concentrations of 1.29 x 10  cm   and mass
    of 2.97 x 10~6 gm cnT2.

b)  Ambient

    The moderately loaded filters contained large (> 5.0 ym) Fe-rich
    mineral and Fe spherical particles.   The smaller particles were
    similar in composition to the preceding sample.

c)  Hot Metal Charge

    This sample was  heavily loaded with iron and carbon particles
    (Fig. 6).  The larger Fe spheres (> 3 ym) were only distinguished
    from smaller Fe  particles by the presence of more surface morph-
    ology:  average  size 4.07 ± 1.27 ym, concentration = 1.10 x 10^
    cm~2, mass concentration = 2.02 x 10~^ gm cm~ .  The smaller Fe
    particulates (Fig. 7), which were somewhat spherical, had a mean
    size of 0.86 ± 43, concentration of 1.10 x 10  cm   and approximate
    mass of 1.90 x 10~-^ gm cnf .   The small carbon particles (e.g.
    those not indicated in Fig.  7) were highly concentrated in agglom-
    erates; size was difficult to assess but was approximately 0.18 ±
    0.09 ym, which gives a concentration of 9.50 x 10  cm   and a mass
    concentration of 5.80 x 10~° gm cm" .  TEM examination shows a
    relatively stable but relatively nonelectron dense film coating on
    all of these particles (Fig.  8).

d)  Door Leaks

    The samples contained only relatively light concentration of parti-
    cles similar in composition to those produced in the hot metal
    charge.  Some Fe particulates < 0.3 ym in diameter were observed.

e)  Door Leaks During Slag Flush

    Some large (1.0-5.0 ym) mineral particles were observed.  These
    were mainly Ca with some Mg.   Smaller carbon particles were ob-
    served in similar sizes and concentrations as the hot metal charge.

f)  Scrubber

    Particulates observed in association with the scrubber were again
    similar to the carbon produced by the hot metal charge but in
    lower concentrations.  Some particulate agglomerates  (1-5 ym) con-
    tained Fe, K, S.  Many of the smaller particles  (< 1.0 ym) had
    trace amounts of Fe or were composed of Fe.
                             183

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    Fig. 5.   SEM micrograph  of  "encapsulated
              iron particles  produced  by door
              leaks  in  the  open  hearth,  10,OOOX.
03
I
     Fig.  7.   SEM micrograph of  particles pro-
              duced  during  the hot  metal charge
              process  in  the  open hearth,  10,OOOX.
Fig. 6.  SEM micrograph of particles pro-
         duced during the hot metal charge
         process in the open hearth,1000X.
                                                                              1.0pm
    Fig. 8.
TEM micrograph of open
hearth particles, 62,OOOX.

-------
   g)  Tap

       This was  a relatively  lightly  loaded  sample.   Some  large  particles
        (5-2 pm)  of Ca mineral containing Mg,  S  and  Si were  observed.
       Smaller particles  (< 1.0  pm) were mostly carbon  but  a  few mineral
       types were also  observed.

   h)  Limestone Charge

       This sample contained  particulates  similar to  the hot  metal  charge,
       but in reduced concentrations.

   i)  Slag Flush

       Almost identical to those produced  by  hot metal  charge, except
       less concentrated.  Some  spheres  less  than 1.0 pm were not rich  in
       iron, however.

   j)  Bank Cleaning

       No particles observed.

   k)  Fettle

       No particles observed.

} •  Blast Furnace

   a)  Slag Flush

       Large spheres of Fe  (^ 90%) and Ca  (^ 10%);  avg. size =  2.06  ±
       1.01 pm,  concentration =  1.41  x 10  cm   mass  concentration  =  3.36
       x 10   gm cm   were observed.  But  numerous  small particles  rich
       in K and  S  (Fig. $) dominated  the sample. Morphology  can be more
       easily observed  in high resolution  transmission  electron  micro-
       scope (Fig. 10).  The  average  size  was 0.24  ±  0.15  pm, concentra-
       tion = 1.49 x 10 cm~^ and mass concentration  -  2.80 x 10"-3  gm
       cm~2 assuming a  specific  gravity  of 2.6. The  material produces  an
       electron  diffraction pattern and  is therefore  crystalline.   The
       particles were also observed to partially disintegrate in an in-
       tense focused electron beam.

   b)  Hot Metal Tap

       Lightly loaded - a few large Fe spherical particles similar  to
       those found on the slag flush  sample.   Carbon  associated  with
       this sample is composed of agglomerates of carbon made up of par-
       ticulates < 0.1  pm in  diameter.

   c)  Hot Metal Runner

       Filter virtually without  particles.
                                185

-------
Fig. 9.  SEM micrographs (1,OOOX and 10.000X) and X-ray spectra of particles produced during blast furnace
         slag flush operations.

-------
SC
•
         Fig. 10.  TEM micrograph of particles
                 produced during blast furnace
                 slag flush operations,  23,OOOX.
                                                         Fig. 11.  SEM micrograph of particles produced
                                                                 during sintering plant operations.
                                                                 1000X.
Fig. 12.
          £W$'tf$&&
        -•* A-^%'  '^   •
                                                                 SFH micrograph of particles produced
                                                                 during crushing operatins at the
                                                                 Heckett Engineering site, 1000X.

-------
d)   Slag Tap

     Sample composition almost  identical  to Slag Flush but contains more
     large Fe  spheres.  Surface of  these  spheres morphologically  smooth-
     er than those being produced in  the  open hearth.  Average size »
     1.74 ± 1.29, concentration B 1.26 x  10^ cm" , mass concentration •
     1.81 x lO"-* gins cm~2.

Sintering Plant

All  sintering plant samples were characterized by the almost total lack
of carbon particles, spherical particles and particles less than 1.0
ym.  The samples contained large angular particles  (Fig. 11) rich in
Ca and/or Fe.  If we assume an  average density of 4.0 the estimated
avg. size = 4.03 ± 2.35 vim and  concentration - 7.77 x 10^
mass concentration is estimated at 1.07 x 10"^ gm cm~2
particulates of carbon or coal were also observed.

Heckett Engineering^
                                                                   cm
                                                                     -2
                      the
               Some large
         Overall, all samples collected in Heckett Engineering location con-
         tained almost exclusively large particles of a mineral composition
         (i.e. calcites and silicates); small (< 1.0 ym) carbon or Fe particles
         were not observed on any of these samples (Fig. 12).  The predominant
         species was a calcium silicate (Figs. 13 and 14), similar in composi-
         tion to the minerals epidote and dolomite.
Fig, 13.  Typical x-ray spectra of an    Fig. 14.
          individual particle collected
          during crushing operations.
Typical x-ray spectra of an
individual particle collect-
ed during crushing opera-
tions.
                                      188

-------
B.  Ambient Samples

    Specific information on ambient sample sites has not been made available
at this time.

    1.  Station. 1

        All samples for this sampling site were heavily loaded.  Overall X-ray
        emission spectra for November 7. 13, 16 and 18 are presented in Figure
        15.  From this information it is readily observable that elemental sul-
        fur became most abundant on November 16 and elemental iron on November
        18 (one of the highest levels observed on ambient samples).  In both
        cases this is the result of relatively large particles containing cal-
        cium and sulfur or, respectively, Fe-rich minerals.

    2.  Station _2

        The November 8 sample was heavily loaded with large mineral particles
        which were mainly calcium silicates and silicon (quartz).  One very
        large Fe sphere (9 ym) was observed.  Iron and iron-rich particles
        were observed in sizes greater than and less than 1.0 ym in diameter.
        Particles rich in sulfur were also observed, sometimes with trace
        amounts of elemental lead.  Some micron size spheres of carbon were
        also observed.  Sulfur was associated with carbon particles and was
        very high in concentration producing an overall high bulk sample sul-
        fur concentration (Fig. 16).  The November 11 sample was much less
              Fig.  16.  X-ray  bulk  spectra  from  particulates
                        collected November  11, at  site  2.
                                      139

-------
           November 7
 November 13
        November  16
November 18
Fig. 15.  X-ray spectra of bulk samples collected at ambient site 1, November
          7, 13, 16 and 18, 1977
                                      190

-------
    heavily loaded but contained relatively more large (>  1.0 ym)  iron
    particles than the November 8th sample.

    The November 14 sample was virtually void of particulates and  no Fe-
    rich particles were observed.

    The November 17 sample contained a moderate particulate load.   Most of
    the larger particles were calcium or calcium silicates.  A few Fe
    spheres about 2.0 ym were observed.   Only a few small  (< 1.0 ym) Fe
    particles were noted.

3.  Station 3

    The November 9 sample was heavily loaded.  The larger  particulates were
    almost entirely mineral.   Two species of iron particles:  individual
    spheres approximately 0.5 um in diameter and agglomerates of particles
    < 0.2 ym in diameter were observed.

    The November 12 sample was less heavily loaded, contained a large Fe
    sphere 2 ym in diameter and contained less small (< 1.0 ym) Fe particu-
    lates than the November 9 sample.  Relatively high concentrations of
    sulfur were observed with the small carbon particulates.

    The November 15 sample was similar in composition to November  12 except
    for reduced amounts of material.

    The November 18 sample exhibited increased amounts of  material.  There
    was a significant increase in the observed number of large Fe  mineral
    particles.  Small Fe particles were also present as 0.2 ym spheres.
    Sulfur-rich particles were observed; the morphology was consistent with
    carbon particles observed earlier.

4.  Station 4
    The November 8 sample was heavily loaded.  Large angular particles of
    Fe and Fe silicates were observed as well as a few Fe spheres.  Small
    particulates included Fe and Fe silicates; a few particles rich in Cu
    and Zn were also observed.

    The November 11 sample contained only a few large particles (none over
    3-4 ym in length).  The small particles were predominantly carbon
    spheres < 2.0 ym and carbon plates/spheres; one agglomerate of Fe
    particles was observed.

    The November 14 sample was very clean.  No small Fe particles were
    observed, and the number of carbon particulates was greatly reduced.

    An increase in particulate loading on the November 17 sample was ob-
    vious.  The large angular particulate fraction contained a high propor-
    tion of Fe or Fe-rich particulates.  An increase in small carbon and Fe
    spheres  (^ 0.2 ym) was also evident at higher magnifications.
                                  191

-------
 5.   Station  5

     Samples  collected  on November 7 and 10 were heavily loaded with large
     particles  (Figs. 17 and 18).  The  sample collected November 13 (Fig.
     19) was  less  loaded and the  sample collected November 16 had virtually
     no particulates of any kind.

     On November 7 some of the larger angular particulates contained Fe or
     Fe silicates which were 4.97 ± 1.75 um in average effective diameter.
     Carbon particulates of two distinct types were observed at higher mag-
     nification  (Fig. 18); iron-rich particles were present in relatively
     low concentrations.

    No iron  silicates were observed in the sample collected November 1O
     however, Fe particulates were observed, most were spherical (^ 2.0 um)
     in shape.

    The November 13th sample was lightly loaded but did contain a number of
    angular  particulates ^1.0 ym which were mostly mineral silicates al-
    though some were carbon and iron (pollen was also present).  Some car-
    bon spheres approximately 1 ym in diameter were observed.   Particulates
    < 1.0 um were present in very low concentration, and only one submicron
    Fe particle was observed.

6.  Station _6

    The November 12th sample was unique in that it contained a number of
    large flyash and carbon particles with high concentrations of potassium
    Some spheres containing Fe were noted.   The smaller size particle frac-
    tion contained Fe (0.2 um) and sulfur-rich carbon particulates.

    The November 18th sample was void of  particles > 2 um and  contained
    only a few carbon and Fe particles about 0.2 ym.

7.   Station 8

    Samples were collected at  this location consecutively from November 7th
    through  I Bib.   Particle loading was heavy the 7th and increased  the 8th
    Some reduction was  noted the 9th and  10th;  the llth and  12th exhibited
    even heavier loads.   Some  reduction was noted the 13th;  and by the 14th
    the level of particulates  had been reduced  most significantly.   From
    the 15th through the  18th  the amounts  of  material continued to rise to
    levels experienced  November  7.

    Most  of the large particulates noted  on the 7th were mineral;  none were
    Fe and only a  small percent  were Fe rich.   A significant number  of
    spheres > 1.0  um were observed which were composed of  carbon but  also
    contained a significant  amount of  K;  others were siliceous  or  PbBrCl.
    The smaller particulates observed  were  carbon (0.1 um);  some spheres
    (^ 0.6 um)  of  carbon,  and  Fe (0.3  um) were  also observed.   Material
    rich  in sulfur was  also  present.

    The sample  collected  the 8th was very heavily loaded but had  a compo-
    sition similar to that of  the previous  day  (Fig.  20).  More carbon

                                  192

-------
     Fig.  17.   SEM micrograph,  Ambient  Site 5,
               November  7,  200X.
-
    Fig. 19.  SEM micrograph, Ambient  Site 5,
              November 13,  10,OOOX.
                                                                                                         * I.Ojim
            SEM micrograph, Ambient Site 5,
            November 7, 5,OOOX.
Fig. 20.  SEM micrograph, Ambient Site 8,
          November 8th, 2,OOOX.

-------
     particulates (0.5 ym)  were evident than previously observed;  these,  and
     the finer carbon particulates,  contained trace amounts of  sulfur.  This
     proportion of particulates remained the same through the 13th.   On the
     llth no large Fe or Fe-rich particulates were observed,  though  the
     sample was heavily loaded; the  small Fe particulates,  e.g.  Fig.  21,  had
     a mass concentration of 5.95 x  10~^ gm cm~2.   The amount of sulfur
     associated with the numerous carbon particles was observed  to have in-
     creased since November 8th.

     The 13th,  one large (3.6 urn) Fe sphere in a 1000X field  was observed.

     The November 14th sample was the cleanest of  Station 8.  However,  iron
     spheres (1-2.5 ym)  were observed,  as well as  some small  (<  1.0 ym) Fe
     particles.   Particulates observed  on the 15th were similar  to those  of
     the 14th;  some particles (^  0.5 ym)  containing calcium and  sulfur  were
     also observed.

     The large  particle  fractions of sample 16 were predominantly  mineral
     and carbon (automotive);  a few  Fe  spheres and Ca-S particles  were  ob-
     served.   A few submicron Fe  and Ca-S particles were also observed.
     Figure 22  illustrates  some of the  typical small particles observed on
     this sample.

     Samples  collected on the  17th and  18th are very similar  to  those col-
     lected the  16th with a  slight increase in concentration.

8.   Station  9

     Samples  were  collected  consecutively  from November  8th through the 17th.
     The  most distinctive feature of  these samples  is  that no large Fe
     particles  are  observed  (only one large angular  Fe-rich particle was
     observed in all the  samples).   A few  micron size  Fe  particles were ob-
     served in  the  sample collected November  17th.   Particulate  loading was
     heaviest November 8-11, reducing in amount  through  the 12th and 13th to
     a low  level the  14th which then  remained  relatively  continuous through
     the  17th.   Submicron size particles rich  in copper and lead-arsenic
    were observed in a number of samples.

    On November 9th,  large carbon particles 2.92 ±  1.31 ym and smaller par-
     ticles > 1.0 ym were observed.  Figure  23  illustrates some of these
    particle types.  Sulfur was observed  to be associated with both carbon
    types.

9.  Station 10

    November 8 and 9 - very heavy loading.  Though  large clay (Al,Si,K,Ca,
    Fe) and quartz particles were present, the filters were observed to
    also contain high concentrations of small particles.  Most of the sub-
    micron size carbon particles were rich in sulfur, producing a high sul-
    fur concentration for the entire sample (Fig. 24).

    November 10 and 11 - heavily loaded but reduced from the 8th and 9th.
    Large particles still predominant,  but some large carbon particles
    apparent.  More larger (.4-1.0 ym)  submicron size particles observed;

                                  194

-------
    Fig. 21.  SEM micrograph, Ambient  Site 8,
              November llth, 10,OOOX.
               Fig. 22.  SEM micrograph,  Ambient Site 8,
                         November 16th, 10,OOOX.
c
    Fig. 23.  SEM. micrograph, Ambient  Site  9,
              November llth, 10.000X.
Fig. 24.  X-ray spectra from a bulk sample collected
          from ambient sampling site 10, November 9.
          The sulfur peak is produced by sulfur adsorbed
          onto carbon particles.

-------
         they  are  probably  carbon with  adsorbed  sulfur;  some  iron agglomerates
         also  present  (Fig.  25).  Overall  sulfur  concentration was the highest
         of  any  ambient  or  source sample on  sample  10 and was almost entirely
         associated with particles  less than one  micrometer in average diameter.
         By  November llth,  sulfur concentration  had been reduced to 1/3 of that
         of  the  10th.

         November  12-13  - sample loading reduced  from the previous samples; com-
         position  essentially  the same.  Individual small particles (> 0.5 urn)
         of  Fe and Cu  observed.

         November  14-15  - Samples lightly  loaded.  On the 14th, only small (0.1
         ym) and large (0.5  ym) carbon  particles  were observed.  By the 15th,
         particles had increased in concentration; small (< 0.5 ym) Fe particles
         were  also observed.   Carbon particles contained only traces of sulfur.
         A few submicron size  Cu particles were observed on the 15th.

         November  16-18  - Sample loading became progressively heavier after the
         15th.   Particulates observed in the  larger size fraction continued to
         be  mainly mineral,  some Fe spheres  and Fe-rich angular particulates.
         In  the  smaller  size fraction,  carbon particulates were observed to in-
         crease.   Fe and Ca-S  particulates were also observed.

         Estimated filter concentration values for large and small carbon par-
         ticulates and iron-rich particulates spherical in morphology are pre-
         sented  in Appendix Table A.
                                  DISCUSSION

     The following particulates produced by the U.S. Steel Corporation, Geneva
Plant could be potentially useful in assessing fugitive source emissions from
specific areas within the plant:

1.  Carbon particulates small spheres approximately 0.1 ym in diameter, often
    found in agglomerates, are produced during the coking, open hearth and
    blast furnace processes.  Particulates of this type were observed in all
    ambient samples.  However, there are other sources for these particulates
    notably the automobile.  Careful analysis would be required to use these
    as source emissions indicator.

2.  Carbon particulates approximately 1.0 ym in diameter having a definite
    spherical shape are produced during the coking process.  These particulates
    were observed at most ambient stations, usually in low concentrations.
    They are apparently unique to the Geneva Steel  Works.

3.  Carbon particulates - spheres or plate-like particles ^ 0.30 ym in diame-
    ter produced by door leaks after slag charge.  Similar particulates have
    been observed at a number of ambient sites.  They are apparently somewhat
    unique, although they might be indistinguishable from some particulates
    produced during coking operation.

4.  Iron spheres - spheres containing mainly Fe produced in a size range from
    > 5 ym to < 0.3 ym.   The most productive source is probably the hot metal

-------
Fig. 25.  SEM micrograph, Ambient Site 10,
          November 10, 10.000X.
Fig. 26.  TEM micrograph, Ambient Site 10,
          sulfur-rich carbon particle, 20,OOOX.
                      19 /

-------
      charge section of the blast furnace, although these particles are produced
      in other open hearth and blast furnace sections.  They are unique to the
      plant.  The larger (> 1.0 ym) spheres produced in the open hearth and blast
      furnace areas may be morphologically different.   Such iron spheres both
      large and small are found in low concentrations  in almost all ambient sam-
      ples.

  5.  Potassium-sulfur particulates 0.2 ym in diameter are produced only in the
      slag flush and slag tap sections of the blast furnace.   They are unique to
      the steel plant.  However, similar particles were found rarely only in a
      few ambient samples.

  6.  Large Fe and Fe-rich angular particles > 2.0 ym  in effective diameter are
      produced during sintering pJant operations.   These particles could be used
      as a source indicator,  but cannot be considered  unique.   A carefully
      applied statistical program coupled with meteorological information would
      be required to assess their potential as a spot  source  indicator.

  7.  "Encapsulated" iron particles (0.4 ym) produced  during  door leaks after
      slag charge.  These particulates have a non-spherical structure,  and mor-
      phological "halo" surround a central core.   Similar particulates  have been
      found in some ambient samples.

       Carbon particles are usually identified by  their conspicuous lack of ele-
  ments  with an atomic number greater than sodium.   An observation made at all
  ambient sites was that the  levels of sulfur associated with these types of
  particles were dependent  upon the length of time  that the local air mass had
  remained stagnant.   In Figure 26,  a TEM micrograph of one of the sulfur-rich
  carbon samples is displayed;  these  particles did  not produce an electron dif-
  fraction pattern and were stable in a focused beam.   No morphological differ-
  ences  were noted between  particles  with and without  a sulfur association.1

      A separate analysis  for  large  angular iron-rich mineral particles was
  conducted to determine the  feasibility of  using  the  sintering plant fugitive
  emissions as a local specific indicator.   A table of these  data is provided in
  Appendix Table B and a summary is  presented in Fig.  27.   Sites 5 and  9 are
  respectively close  to the steel plant.

      On about  November 13 a storm front moved through the region.  Using mass
  estimated  (Appendix  Table A)  it  is  possible to examine changes in particulate
  concentration  probably associated with the Geneva Steel Plant  operation as  the
  air mass  in  the  Provo area  is cleared  and  the rate at  which  these particulates
  return to  previous  levels (Fig.  28).   It  should be noted  that  at  this  stage of
  refinement  these values are not  corrected  for flow rates  and sample times and
  are therefore  comparative in  nature.
I/
  This topic is covered in more detail in Russell (1979)
                                       19J

-------
           100%-
                     iFe >80
                  n
Ft 80 - 20
                     IF. <20
           50%-
Fig. 27.   Particle analysis for  iron rich species,
                                199

-------
          5 x 10 ' -
                        CAtlON <0 Jp.
O
o
          1 x 10  —
            .0-*-
                                                            1  t. -  I
                                    Fig.  28.  Ambient particle analysis summation.

-------
                                   CONCLUSION
   A microscopic inventory of particulates can provide invaluable assistance in
assessing the nature and inhomogeneities of fugitive source emitters. Particles
that are, in turn, unique can be identified some distance from the emitter. With
suitable sampling parameters, estimates can be made for number and mass per unit
of air.
                                        201

-------
                               REFERENCES CITED

Ruud, C. 0., C. S. Barrett, P. A. Russell and R. L. Clark.  1976.  Selected
area electron diffraction and energy dispersive x-ray spectrometry, a compari-
son.  Micron.  7:115-132.

Russell, P. A.  1979.  Carbonaceous particulates in the atmosphere:  illumina-
tion by electron microscopy.  Pages 133-140 ^n T. Novakov (ed.), Proceedings:
carbonaceous particles in the atmosphere.  LBL-9037.  NTIS, Springfield, Va.
                                    202

-------
              APPENDIX A




MASS ANALYSIS OF PARTICLES COLLECTED ON




   AMBIENT THIN MEMBRANE SUBSTRATES
                  203

-------
          Appendix Table A

Estimated mass collected on ambient
     site thin membrane filters
                                n
          Estimated Mass (gin cm  )
Sample
1-7
1-13
1-16
1-18
2-8
2-11
2-14
2-17
3-9
3-12
3-15
3-18
4-8

4-11
4-14
4-17
5-7
5-10
5-13
5-16
6-12
6-18
8-7
8-8
8-9
8-10
8-11

8-12
8-13
Carbon (< 0.3 ym)
3.02 x 10-6
3.18 x ID"6
2.39 x 10~6
1.75 x 10~6
2.71 ± 0.91 x ID"6
1.05 ± 0.66 x 10~6
1.13 x 10" 7
1.01 ± 0.41 x ID"6
2.19 x 10-6
1.33 x 10-6
5.62 x 10"7
6.22 x 10"7
^ 5.0 x 10~7

1.21 x ID'6
5.47 x 10"7
1.18 x 10"6
4.70 ± 0.73 x 10"6
7.56 ± 0.27 x ID"7
2.12 ± 0.71 x ID"7
2.25 x ID"8
5.32 x KT7
9.22 x 10~8
1.67 x 10~6
2.60 x 10~6
1.76 x 10~6
9.35 x 10" 7
8.17 x 10- 7


3.03 x 10"7
Carbon (> 0.3 ym)
1.11 x 10-6
1.23 x 10-6
2.09 x 10~6
j.,84 x 10~6
^^
_ _
__
—
8.03 x 10"7
1.01 x 10-6
6.26 x 10~7
1.37 x 10~7
1.50 x ID"6

2.07 x ID-6
1.50 x. 10~7
2.37 x 10-7
2.34 x ID'6
2.99 x 10~7
__
—
2.44 x 10~7
—
6.07 x 10~7
2.84 x 10-6
1.57 x 10- 7
9.25 x ID" 7
3.01 x 10~6

1.93 x 10"6
8.07 x 10~ 7
Fe
1.37 x 1C-5
1.50 x 10-6
1.17 x 10"6
1.34 x 10~6
3.26 x 10-6
1.39 x 10~7
—_
2.26 x 10~7
4.69 x 10"6
1.25 x ID"6
8.25 x 10~7
3.19 x 10"7
1.82 x 10~5
(Fe-rich mineral)
1.78 x ID'7
	
8.67 x 10-8
7.80 x 10~7
3.74 x 10-7
«••
—
1.37 x 10~7
1.71 x 10~8
4.46 x 10~8
2.06 x 10~7
3.14 x 10- 7
7.64 x 10~8
1.12 x 10~6
(1 Irg. part.)
3.25 x 10"8
2.31 x 10~7
Other
8.84xlO~7
(PbBrCl)
4.69xlO~7
(flyash)




—



—




—



—
3.19x10-6
(mineral)



~




                              (1 part.)
               204

-------
                           Appendix  Table A (Con't)


                                                       o
                             	  Estimated Mass (gm cm

Sample     Carbon_(< 0.3 ym)     Carbon (> 0.3 ym)       Fe

                                                     6.19 x 10"7
8-14
8-15
8-16
8-17
8-18
9-8
9-9
9-10
9-11
9-12
9.
1.
1.
2.
1.
1.
1.
1.
3.
7.
28
06
82
98
99
40
66
19
35
79
x
x
X
X
X
X
X
X
X
X
io-7
10~6
10~6
10~6
io-6
io-6
10- 6
10" 6
10- 6
io-7
6

6
6
6
5
5
9
8

.57

.80
.12
.44
.30
.67
.30
.42

x
-
X
X
X
X
X
X
X
—
io-7
-
io-7
io-7
io-7
io-7
10~6
io-7
io-7

                                                                   3.61 x  10~7
                                                                      ("CaS")
                                                     1.44 x 1(T6   1.07 x  10~6
                                                                      ("CaS")
                                                     2.77 x 1(T7   2.43 x  10~6
                                                                      ("CaS")
                                                     9.17 x l
-------
          APPENDIX B




ANALYSIS OF IRON-RICH MINERAL




          PARTICULATES
              206

-------
                                                    Appendix  Table  B



                                 Analyses  of  particles  >^ 5.0ym on  thin membrane samples

                                        S-10-6,  5-7  and  ~9-3 from Geneva Steel Works
o
-J


Sample
S-10-6
5-7
9-13
Fe >
80%


35.9
4.8
0
	

Si
11.5
2.4
4.8
JSr.5.
Si &
Ca
6.5
2.4
0
su*

Ca
1.3
0
0
	 	

Total
19.3
4.8
4.8
— 	

Si
19.2
25.0
39.3
	
Si &
Ca
7.7
35.7
13.1
Fe __<

Ca
6.4
22.6
40.5
^_

Other
2.8
3.6
1.2
	

Total
37.1
86.9
94.1


Carbon
7.7
3.6
1.2

-------
              DEVELOPMENT OF HORIZONTAL ELUTRIATORS  FOR SAMPLING
                   INHALABLE PARTICULATE FUGITIVE EMISSIONS
                                      by
                              Kenneth M. Gushing

                         Southern Research Institute
                           2000 Ninth Avenue, South
                          Birmingham, Alabama 35205
                                   ABSTRACT
     The U.S. Environmental Protection Agency  (EPA)  is required, under the
amended Clean Air Act of 1977, to review the scientific basis for the total
suspended particulate  (TSP) ambient air quality standard and determine whether
a revised particulate standard can be promulgated by December, 1980.  It has
been recommended that research to develop information for a size-specific
standard should focus on inhalable particulate  (IP) matter as defined as air-
borne particles £15 ym aerodynamic diameter.  This particle size range relates
to that fraction of particulate matter which can primarily depos.it in the con-
ducting airways and the gas exchange areas of the human respiratory system
during mouth breathing.

     This paper addresses the efforts of Southern Research Institute under con-
tract to IERL/EPA/RTP to experimentally apply horizontal elutriation to specif-
ic methods for sampling instack, ambient, and fugitive inhalable particulate
emissions.  Theoretical and experimental data are shown.  Results of the appli-
cation of horizontal elutriation for the initial collection stage of the
Fugitive Assessment Sampling Train (FAST) developed by TRC Environmental Con-
sultants are presented.
                                       208

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                                 INTRODUCTION
     The U.S. Environmental Protection Agency (EPA) is required under the
amended Clean Air Act of 1977, to review the scientific basis for the total
suspended particulate (TSP) ambient air quality standard and determine whether
a revised particulate standard can be promulgated by December 1980.  It has
been recommended that research to develop information for a size-specific
standard should focus on inhalable particulate (IP) matter as defined as air-
borne particles <15 urn aerodynamic diameteri  This particle size range relates
to that fraction of particulate matter which can primarily deposit in the con-
ducting airways and t.;as exchange areas of the human respiratory system during
mouth breathing.  Figures 1 and 2 present some of the data which led to the
specification of the 15 urn IP size standard.  While 100% deposition of particles
during nose breathing occurs above 10 urn aerodynamic diameter, the 100% depo-
sition size for mouth breathing is approximately 15 ym aerodynamic diameter.1
An ideal IP sampler would then separate those fractions of particulate matter
larger and smaller than 15 ^m aerodynamic diameter.

     Figure 3 presents the performance criteria for IP samplers.  It was de-
veloped after extensive discussions between EPA staff members and scientists
knowledgeable in particle sampling methods.8  All samples will be required to
fall within the performance specification indicated by the region shown in
Figure 3.  It is constructed by plotting two lognormal curves, with geometric
standard deviations of 1.0 and 1.7 through the 15 urn ± 2 ym 50% points.  After
allowing 10% wall loss for small particles and 10% penetration of large par-
ticles, the area is completely defined.  The tolerance in the Dso is 15 ym ±
2 ym.

Theoretical Considerations

     A variety of aerosol sampling systems are being developed for use in mea-
suring the concentration of inhalable particulate  (IP).  The primary perfor-
mance requirement is that each system must separate particles larger and
smaller than 15 ym aerodynamic diameter according to the specified efficiency
curve.

     Cyclones, impactors, virtual impactors, and horizontal elutriators are
devices that possibly can be used to collect the larger particles.  All of
these, however, have features that limit their applicability.  Impactors may
not retain particles efficiently that are much larger  than the stage cut point.
The particles bounce and are reentrained into the gas  stream, resulting in
contamination of the small particle fraction.9'10'11   Cyclones are not subject
to that problem but they are larger and their performance is difficult to pre-
dict.12  Virtual impactors may have significant losses of small particles.13
Horizontal elutriators are bulky and their performance is sensitive to orienta-
tion.  However, for reasonable velocities reentrainment is not a problem in
horizontal elutriators and the theory describing their performance is straight-
forward and accurate.11*

     Horizontal elutriators have been used extensively as devices for measur-
ing and collecting particles and as apparatae for a variety of aerosol

                                      209 •

-------
 experiments.15"1'   The British Medical Research Council adopted the penetra-
 tion curve of a particular horizontal elutriator as the definition of respir-
 able particles.    Mercer has reviewed many of the practical applications of
 elutriators for sampling respirable particles1.*  Hamilton and Walton18 have es-
 tablished the criterion that reentrainment of deposited particles may occur if
 the ratio of the mean air velocity to duct height (rectangular geometry)
 reaches a critical value which lies between 240 and 650 sec'1.

      This paper describes the results of laboratory studies that were carried
 out to develop horizontal elutriators for measuring the IP concentration  in
 fugitive, ambient, and stack aerosols.  Specific designs were  developed for
 use  in conjunction with commercial,  instack,  cascade  impactors,  the EPA's  Source
 Assessment Sampling System (SASS),20 and the EPA's Fugitive Assessment Samplina
 Train (PAST)."                                                                9

 Background Discussion

      The initial  concept of the horizontal elutriator was the  result  of studies
 to  measure quantitatively the deposition of aerosol particles  on surfaces  ad-
 jacent to aerosols flowing through laboratory apparatus.   Natanson22  and
 Thomas23  independently solved this problem for particle settling in a circular
 horizontal tube.   Although the derivations are somewhat complex, the  results
 can  be summarized  and simplified in terms of the collection efficiency (Eff)  by
 the  following equation:
                            -1/3 ./I  _  e-Lt 3   J.  -,,-„„,•„  ~l/3
    Eff = - 2c /I - e"3   e1/3 /I - e"4  + arcsin e1"              (1)


where
        3V gL
    e = 	—  and
        8 aV
   V  is the settling velocity,
    s
    L is the length of tube,
    a is the radius of tube, and
    V is the average velocity of the gas.

     The theory describing the performance of a rectangular, flat-plate elu-
triator is considerably less complex and is re-derived here to give the reader
a better understanding of the particle motion in the elutriator.
     The settling velocity of spheres in a gas stream is given by the equation

                                V
                                     Cpqd2
                                 s    18n

where

     g is the acceleration due to gravity,
     C is the slip correction factor,
     p is the particle density,
     d is the particle diameter, and
     n is the viscosity of gas.
                                      2IC

-------
     In health-related studies,  the aerodynamic behavior  of  the  particles  is of
interest.  It is therefore convenient to relate the  settling velocity  of all
particles, whatever their shape  or  density,  to that  of  spheres having  unit den-
sity.  The aerodynamic diameter  is  defined as  the diameter of a  unit density
sphere having the same settling  velocity as  the particle  of  interest.  The
aerodynamic diameter is given from  Equation  2  by settling p  = 1  g/cm3  (the
units must be retained).  Also,  for particles  larger than about  2  ym,  the  slip
correction factor is approximately  equal to  unity.   A graph  of settling velo-
city vs. diameter is shown in Figure 4.

     For fully developed flow between parallel plates,  the velocity profile of
a gas is parabolic with the maximum velocity equal to 3/2 the average  and  with
zero velocity at the plates:

where
     V  is the velocity parallel to the plates,  at a point y,
      X
      y is the displacement above the bottom plate,
      h is the spacing between plates, and
      V is the average velocity of the gas.

     The velocity profile and a typical particle trajectory are illustrated in
Figure 5.

     The efficiency with which particles are collected is determined by the
dimensions of the channel, the velocity of the gas, the settling velocity of
the gas, the setting velocity of the particles,  and the height at which the
particles.-enter the channel.

     Consider a particle which enters the channel at position y  as shown in
Figure 6 and which has a trajectory of horizontal length L (the°length of the
channel).  Neglecting diffusion, which is negligible for the particles of in-
terest, all particles of this diameter or larger entering at or below position
y  will be captured.  All particles of this diameter entering the channel at
positions higher than y  will penetrate the channel.
Thus
                                dx = /6y. _ 6£\ -
                                dt   {  h   h2  / V
but dy is given by dy « V dt, therefore
                         s
                                            -*)
dy; and
                                                  V  ,               (4)

from which the length of the channel needed to capture  particles of a particu-
lar diameter may be determined.

                                       211

-------
      If the particles are uniformly distributed within the gas, the fractional
 collection efficiency of the particle illustrated in Figure 5 is equal to the
 ratio of the volume of gas passing below position y , to the total volume; thus
                          Eff.
                                            V dy
                                             x •*
                                         14


                                    W   /  V
                                             X
                                        o
 where W is the width of the channel.

      Now,  from Equations 2 and 4,
                      r,ff
                      Eff.  *  -3- » — *-^ —  .                        (5)
                              hV    18r|hV

      The  theoretical  efficiency curves  for a horizontal elutriators  with a
 circular  cross-section (from Equation 1)  and for  a horizontal  elutriator with a
 rectangular  cross-section  (from Equation 5) , both designed to  have a cut point
 of  15 urn  aerodynamic  diameter,  are shown for comparison in Figure 7.

      The  efficiency is found to be independent  of the  vertical velocity  profile
 and,  as Fuchs1** observed,  Equation 5  can also be  derived assuming plug flow.

 Experimental Procedures and Results

      Experiments were conducted to verify Equation 5 and to set design para-
 meters for the IP  samplers.

      Figure  8 is a schematic diagram  of the  experimental apparatus used  to in-
 vestigate the performance  of a  horizontal elutriator designed  to have a  cut
 point (D50)  of 15  \an  aerodynamic diameter.   The settling chamber consists of
 28 channels, each  7 mm high,  17.8 cm  wide, and  38.1 or  20 cm long.  A high vol-
 ume blower (Model  305,  Sierra Instruments) connected in series with a variable"
 voltage transformer was  used to supply  the desired air  flow rate through the
 chamber.  Monodisperse  particles of methylene blue were generated using  a vi-
 brating orifice aerosol  generator.  During each test, the particles were sam-
pled  and  checked frequently  by  optical  microscopy to insure constant monodis-
persity.  All particles  entering the  horizontal elutriator  were  collected
either by settling on the  plates or on  the 8 in.  x 10 in.,  (20.3 cm x 25.4  cm)
 filter placed downstream from the plates.                                '     '

      Upon completion  of  each test,  the  plates and filter  were  washed separatel
with  tap  water.  Samples from each wash were centrifuged  to remove debris  an*^
the masses of methylene  blue  collected  on the plates and  on the filter were d
termined  by absorption  spectroscopy.

     A study of the velocity  distribution through  the settling chamber was mad
 to determine the configuration  necessary  to obtain uniform  flow.  The use of

                                      212

-------
two filters and an extended, flared inlet was necessary to provide the desired
velocity distribution.  Figure 9 is a velocity profile measured using a thermal
anemometer immediately upstream from the blower before the plates were in posi-
tion.  From these data, it was evident that the blower was pulling uniformly
across the rectangular opening where the two 8 x 10 in. filters were positioned
Figure 10 shows the velocity profile measured upstream of the collector plates
with the extended, flared inlet in position.

      The velocity profiles shown in Figures 9 and 10 were considered satisfac-
tory, and the overall average velocity was used to calculate the theoretical
performance curves for the system.  The average velocity through the chamber
measured using the thermal anemometer was in agreement with previous calibra-
tion of the blower.

      Two sets of experimental data were obtained from the testing of the hori-
zontal elutriator.  The first set was acquired while operating the settling
chamber at an average gas velocity of 70 cm/sec and a plate length of 38.1 cm.
The second data set was obtained by operating the system at 40 cm/sec after
shortening the plate length to 20 cm.  The theoretical curves of the collection
efficiency versus aerodynamic particle diameter shown in Figures 11 and 12 were
developed from Equation 5 using the following parameter values:

                    Figure 11                    Figure 12

                    p = 1.35 g/cm3               p = 1.35 g/cm3
                    g = 981 cm/secz              g = 981 cm/sec2
                    L=38.1cm                  L=20cm
                    n - 181 x 106 poise          n = 181 x 106 poise
                    h = 0.701 cm                 h = 0.701 cm
                    V = 70 cm/sec                V = 40 cm/sec
                    Reynolds No. - 315           Reynolds No. = 180
                    V/h = 100                    V/h = 57

      The calculated values from theory for the collection efficiency were
found to be in excellent agreement with the measured values.  No corrections
were made for end effects.

      The experiments described above indicated that the theoretical equations
can be used to predict particle collection by horizontal elutriators to a high
degree of accuracy.  Consequently, the equations were used to create design
nomographs for IP precollectors to be used in conjunction with the three sys-
tems of interest.  Design parameters were calculated for horizontal elutria-
tors to be used with:   (1) cascade impactors operated at 14.2 i/min and 149°C,
(2) the Source Assessment Sampling System operated at 125 Jl/min and 204°C, and
(3) the Fugitive Assessment Sampling Train operated at 5,282 Jl/min and 23°C.

      Figures 13, 14, and 15 are the design nomographs for the three sampling
devices.  On the vertical axis is the open area required, neglecting the thick-
ness of the tube walls.  The horizontal axis is the length of the elutriator
required to yield the IP performance at the specified flow rate and temperature.
In constructing the graphs, it is assumed that the rectangular channels have
widths much greater than their heights, so that the vertical walls will not
have a significant effect on the gas flow.
                                       213

-------
 Fugitive Assessment Sampling Train

       The Fugitive Assessment Sampling Train (FAST),  developed  by TRC Environ-
 mental Consultants for EPA,  was designed to obtain 500  milligram samples  in an
 8 hour period downwind of typical  industrial sources.   The  initial prototype
 shown in Figures 16 and 17 consisted of a louvered inlet transform,  a 15  ym
 D-,0  impactor  precollector, a 2.5 ym D$o cyclone,  and  a  back-up  filter.  The
 operating flowrate is 5.28 m3/min.  A 5 CFM side  stream to  an XAD-2  solid sor-
 bent canister is used to measure the organic vapor content  of the sampled gas
 stream.

       Subsequent laboratory calibration of the  precollection impactor by
 Southern Research Institute indicated that it was not operating properly; a
 large number  of particles were bouncing and reentraining.   The  growing interest
 in the inhalable particulate fraction indicated that  some type  of 15 ym D50
 precollector  would still be necessary.  The success that Southern had had in
 the  laboratory evaluation of horizontal elutriators led to  the  decision to de-
 sign a 15 ym  D5a  horizontal elutriator inlet collector  for  the  FAST.  Knowing
 the  flowrate  of the FAST and the size and weight  limitations required by  TRC
 it was a straightforward calculation to determine the specifications for  the
 inlet elutriators.                                                        '

       The final design was for a horizontal elutriator  consisting of 67 slots
 of height 7 mm, and a slot width of 45 cm and length  of 21.5 cm.   in order to
 facilitate removal and cleaning of the elutriator section after each test, the
 plates are mounted in two removal  containers as shown in Figure 18.   Alignment
 pins in each  container hold the 67 plates in position.   Slide type covers can
 be inserted to close off the elutriator section before  and  after  sampling to
 prevent contamination.  See Figures 19, 20,  and 21.   The elutriator  is mounted
 in front of the FAST as shown in Figures 22 and 23.

       After the elutriator was built,  it was shipped  to Southern  Research In-
 stitute  for calibration tests.  The laboratory  set up was as shown in Figure
 24.   Monodisperse 15 ym and 16 ym  aerodynamic diameter  particles  of  ammonium
 fluorescein were  sampled.   The particle generator outlet was moved across the
 louvered inlet section to simulate  a uniform inlet aerosol concentration during
 the  sampling  period.   The particle collection efficiency for these  two
 particle sizes was 47.8% and 58.8%,  respectively  as shown in Table 1.   Figure
 25 shows these data points along with  the theoretical efficiency  curve.   The
 agreement  between theory and experiment is very good.

       The  new Fugitive Assessment  Sampling Train  is now awaiting  its initial
 field  sampling test which  should occur  during the  summer of  1980.

Summary

      Horizontal  elutriation  has been  shown  to  be  an effective and accurate
method for obtaining  inhalable particulate samples.  Application of  the hori-
zontal elutriator method  to  the Fugitive  Assessment Sampling Train has proven
the design extrapolation  to a  full  scale  device.   Future field tests wi^l  de-
termine  the usefulness of  horizontal elutriation under  actual industrial opera-
ting environments.                                                            ""
                                      214

-------
                                   TABLE 1

                FAST HORIZONTAL ELUTRIATOR INLET TEST DATA
Test NO.

Aerodynamic Particle Diameter (ym)

Filter Pressure Drop  ("Hg)

Sampling Duration  (hrs.)
Inlet Louvre Section
  Screen
Screen to Elutriator
 Transform
  Elutriator Plates
  Plate Holder Section
Filter Transform and
  Filter
         1

       16.0

        2.0

        4
                      2

                    15.0

                     2.2

                     2.5
% of
Total Mass
0.75*
0.0009*
3.63
56.2
0.5
% Coll.
Eff.
0.75
0.0009
3.65
58.8
1.27
% Of
Total Mass
28.2
5.34
1.56
31.2
0.14
% Coll.
Eff.
28.1
8.4
2.4
47.8
0.4
38.9
100.0
33.7
100.0
                           *Questionable results due  to  inaccurate washing
                             technique.
                                       215

-------
 References

  1.   F.  J. Miller,  D.  E.  Gardner,  J.  A.  Graham,  R.  E.  Lee,  Jr.,  "Size Con-
      siderations  for Establishing  a Standard for Inhalable  Particles, " J. Air
      Pollut.  Contr. Assoc.f  29(6) :610 (1979).

  2.   M.  Lippmann, "Deposition and  cleanance  of  inhaled particles  in  the human
      nose," Ann.  Otol. 70:519 (1970).

  3.   R.  F. Hounam,  A.  Black,  and M. Walsh,  "Deposition of aerosol particles  in
      the nasopharyngeal region of  the human  respiratory tract," Nature 221:1254
      (1969) .

  4.   G.  Giacomelli-Maltoni, C.  Melandri, V.  Prodi,  and G. Tarroni, "Deposition
      efficiency of  monodisperse particles in human  respiratory tract," Amer.
      Ind.  Hyg.  Assoc.  J.  33:603 (1972).                                    "

  5.   A.  Martens and W. Jacobi,  "Die in-vivo-Bestimmung der  Aerosol teil-chendep-
      osition  in Atemtrakt bei Mund-bzq.  Nazentmung,"  in Aerosole in Physik.
      Medizin  und  Technik, Kongress-bericht der Aerosol tagung  im Taunus-Sana-
      torium am  17.   und 18.,  Oktober  1973 der LVA Wttbg., V.  Bohlau, Ed. Bad
      Soden, West  Germany, Gesellschaft fur Aerosolforschung,  1973, pp. 117-121.

  6.   G.  Rudulf  and  J.  Heyder , "Deposition of aerosol particles in the human
      nose," in  Aerosole in Naturwissenschaft, Medizin  und Technik, V. Bohlau,
      Ed. Proceedings of a conference  held in Bad  Soden,  October 16-19, 1974,'
      Gesselschaft fur  Aerosolforschung 1974.

  7.   Airborne Particles,  National Academy of Sciences,  National Research Coun-
      cil,  Subcommittee on Airborne  Particles, Committee  on Medical and Biolo-
      gical Effects  of  Environmental Pollutants,  1977,  p. 155.

  8.   W.  B. Smith, "Sampling Techniques For Inhalable Particulate Matter",
      Special Report under  EPA Contract No. 68-02-2610, January 16, 1979,
      Southern Research Institute Report No. SORI-EAS-79-031.

  9.   M. Corn and  F.  Stein, "Re-entrainment of Particles  from  a Plume Surface,"
      Am. Ind. Hyg.  Assoc.  J. , 26:325  (1965).

10.   A. K. Rao  and  K.  T. Whitby, "Non-ideal Collection Characteristics of
      Single Stage Cascade  Impactors," Am. Ind. Hyg. Assoc. J., 38:174 (1977).

11.   K. M. Gushing,  J.  D. McCain, and W.  B. Smith,  "Experimental Determination
      of Sizing  Parameters  and Wall  Losses of Five Source-Test Cascade Impac-
      tors, " Ejiyj£pj]u_ScJ^__Technol_. , 13:726 (1979).

12.  W. B. Smith, R. R. Wilson, Jr., and D. B. Harris, "A Five-Stage Cyclone
     System for In-Situ Sampling,"  Environ. Sci. Technol., 13:1387 (1979).

13.  T. J. Yule and  c. G. Bror.iarck,  "An Experimental Study of Virtual  Impac-
      tors,'1 presented at Symposium on Advances in Particle Sampling  and  Mea-
     surement,  Daytona, Florida  (October. 1979).

14.  N. A. Fuchs, The Mechanics of Aerosols, Pergamon Press, New York (1964),
      P.  110.
                                       1 r-

-------
15.  F. Stein, W. A.  Esmen,  and M.  Corn,  "The Shape of Atmospheric Particles  in
     Pittsburgh Air," Atmos. Environ.,  3:443 (1969).

16.  D. Rimberg and J. W. Thomas, "Comparison of Particle Size of Latex Aero-
     sols by Optical and Gravity Settling Methods," J. Colloid Interface Sci.,
     32:101 (1970).

17.  M. Corn, F. Stein, Y. Hammad,  S. Manekshaw, W. Bell, S.  J. Penkola, and
     R. Freedman, "Physical  and Chemical  Characteristics of 'Respirable' Coal
     Mine Dust," Ann. N.Y. Acad. Sci.,  200:17 (1972).

18.  Medical Research Council Panels, cited by R. J. Hamilton and W.  H.  Walton,
     "The Selective Sampling of Respirable Dust," in C. N. Davies, (Ed.),
     Inhaled Particles and Vapors,  Pergamon Press, Oxford (1961).

19.  T. T. Mercer, Aerosol Technology in  Hazard Evaluation, Academic  Press,
     New York, Ch. 8  (1973).

20.  D. E. Blake, Source Assessment Sampling System;  Design  and Development,
     EPA Report No. EPA-600/7-78-018, 221 pp. (1978).

21.  H. Kolnsberg, Ed., Third Symposium on Fugitive Emission  Measurement and
     Control  (October 1978,  San Francisco, California), EPA-600/7-79-182,
     August 1979.

22.  G. Natanson, cited in N. A. Fuchs, The Mechanics  of Aerosols, Pergamon
     Press, New York  (1964), p. 112.

23.  J. W. Thomas, "Gravity Settling of Particles in a Horizontal Tube,"
     J. Air Pollut. Contr. Assoc.,  8(1):32 (1958).
                                      217

-------
                         AERODYNAMIC DIAMETER AT 300 l/min,
                 ui
                 DC
                 CO
                 UI
                 V)
                 O
                     100
1
                               6  8 10
                                                                  20
                      80
         lounam et al. 1969
   	 Q Lippmann 1970
      A Giacomelli-Maltoni et al. 1972
      • Martens & Jaeobi 1973
      • Rudolf & Heyder 1974
70


60
                 -   50

                 O
                         rTJ»Uunamet,,.T1969 '   '   '  «  H/'
                                     100
                            1000
                                10,000
                                700-«2
Figure 1.  Deposition of monodisperse aerosols in the head during inhalation via the nose
          versus D^F, where D is  the aerodynamic equivalent diameter (pm) and F is the
          average inspiratory flow (l/min)2-6   The inspiratory flows in  the individual
          studies of this composite range from 5 to 60 l/min. The heavy solid line is
          the International Commission  of Radiological Protection  Task  Group?
          deposition model.
                                        218

-------
                  100
                   80
             z H
             g&
             g u  60
             UJ Z
             05
             Q t
             UJ
                   40
                   20
                             AERODYNAMIC DIAMETER AT
                           30 l/min INSPIRATORY FLOW, urn
                                      6   8  10
                  20    30
                                      1
        1
                                  1 1 til
      t  I  i  t I mi
                     100
1000
10,000
                                                            700-63
Figure 2. Deposition of monodisperse ferric oxide aerosol in the heads of nonsmoking
         healthy males during mouthpiece inhalations as a function of D?F where D is
         the aerodynamic equivalent diameter (nm) and F is the average inspiratory
         flow in liters/min.  An eye-fit line describes the median deposition between
         10 and 80%.7   The fitted fine has been extrapolated to  15 jum.
                                       219

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to
o
                                                               4       6    8   10            20


                                                                   PARTICLE DIAMETER, /jm aerodynamic
60    80  100
                                                                                                                         4181-30
                                                 Figure 3.  Recommended specifications for collection efficiency of samples

                                                          of inhalable paniculate matter.

-------
0.001
            0.6    1       2       4        8 10      20      40
                PARTICLE DIAMETER, Mm AERODYNAMIC     4181-86

      Figure 4.   Sett/ing velocity in air for unit density spheres.
                                 221

-------
V
Vc
                      Vs    x                  -y
                                                             4181-106
5.   Velocity profile and particle trajectory between parallel plates.
                             122

-------
IT
h  v
   yo
+  t
                                                                       4181-73
                   Figure 6.   Zone of 100% particle collection.
                                     223

-------
u
z
01
0

u
0
u
                        RECTANGULAR

                 	CYLINDRICAL
                 2.0        4.0   6.0  8.0 10         20         40     60   80 100



                        GEOMETRIC MEAN DIAMETER, micrometers

                                                                           4181-233
        Figure 7.   Theoretical collection efficiency by particle settling in rectangular

                   and cylindrical tubes.
                                        224

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COMPRESSED AIR LINE
           REGULATOR
           AND TRAP

           REGULATOR
           DRYER
        I
           ABSOLUTE FILTER
    REGULATOR
      VALVE
ROTAMETERS
 I         I
                VIBRATING
                ORIFICE
                AEROSOL
                GENERATOR
                               FLARED INLET
                           A|R
           DISPERSION AIR
                                                                   FILTER
                                                                              n
                                              SETTLING CHAMBER
                                                                   VARIABLE
                                                                   VOLTAGE
                                                                   TRANSFORMER
                                                                        HIGH VOLUME
                                                                        AIR SAMPLER
                                                                                  I
                                                SYRINGE PUMP                 WATER MANOMETER
                                                               FUNCTION GENERATOR
                                                                                          4181-74
          Figure 8.  Apparatus  used to  measure the collection efficiency of the settling chamber.

-------
                                 V (m/sec)
                                ** 0.30
                                *• 0.20

                                ^ 0.10
STATISTICAL DATA:
  MEAN, x , = 0.24 m/sec
STANDARD DEVIATION,
  Sx = 0.02 m/sec
COEFFICIENT OF VARIATION,
         8.2%
                                                                         4181-107
Figure 9.  Profile of the air velocity immediately upstream from the blower
          of the settling chamber before the plates were positioned.
                                   226

-------
                                             STATISTICAL DATA:
                                                MEAN, x , - 0.23 m/sec
                                             STANDARD DEVIATION.
                                                Sx = 0.02 m/sec
                                             COEFFICIENT OF  VARIATION.
                                                     •• 8.8%
                                                                   4181-108
Figure 10.  Profile of the air velocity upstream from the plates
           of the settling chamber.
                             227

-------
>
o

ui

5
H
u.
UJ

z
g
K
O
O
O
                 2     34      6   8  10         20    30  40


                     AERODYNAMIC PARTICLE DIAMETER, /urn
60  80  100

    4181-109
      Figure 11.   Collection efficiency vs. aerodynamic particle diameter for the

                  horizontal elutriator.  Length = 38.1 cm.
                                      228

-------
u

OJ
LU



0


o
0
U
                  THEORY (RECTANGULAR)

                  EXPERIMENT
                 2     34     6    8  10


                      AERODYNAMIC PARTICLE
     20        40    60   80 100


DIAMETER, ^m            im-232
       Figure  12.  Collection efficiency vs. aerodynamic diameter for the horizontal

                  elutriator.  Length - 20 cm.
                                     229

-------
KJ
U3
O
u
LLJ
Of
ta

O
DC
C
                                                               RECTANGULAR ELUTRIATOR

                         2mm     3mm   456     PLATE SEPARATION
                                                                             NS^Cs^

                                      CYLINDRICAL ELUTRIATOR
                                      RECTANGULAR ELUTRIATOR
                                                                TUBE DIAMETER  2mm
                                                                                       CYLINDRICAL ELUTRIATOR
                                      2.0
                              3.0    4.0   5.0   6   7  8  9 10

                                                    LENGTH, cm
                                                                                          20
30
40   50  60 70

       4181-124
                                   Figure 13.  Relationship of design parameters for horizontal elutriators with
                                              DSQ outpoints of 15 yjm aerodynamic diameter used as precollectors
                                              for instack cascade impactors.

-------
CROSS-SECTIONAL AREA VS. LENGTH FOR 15 /urn AERODYNAMIC CUT POINT
                           RECTANGULAR  ELUTRIATOR
                            8   PLATE SEPARATION
     CYLINDRICAL ELUTRIATOR
     RECTANGULAR  ELUTRIATOR
                                                i  3mm  ; 4mm p56;
                                        CYLINDRICAL ELUTRIATOR
                             LENGTH, cm
40   50   60    80  100

              4181-123
 Figure 14.   Relationship of design parameters for horizontal elutriators with
                outpoints of 15 nm aerodynamic • SASS.

-------

                                             RECTANGULAR ELUTRIATOR

           2mm      3mm  4mm   5   6  7  8   - PLATE SEPARATION
<
_
DC
u
LJ
tfl


S


£
U
    600
    500
    400
    300
    200
                  CYLINDRICAL ELUTRIATOR

                  RECTANGULAR ELUTRIATOR
    100
     50
     40
       10
80  100

LENGTH, cm
200
300   400  500
700    1000

   4181-125
                        Figure 15.   Relationship of design parameters for horizontal elutriators with
                                       outpoints of 15 ysn aerodynamic diameter - FAST.

-------
Figure 16.   Fugitive assessment sampling train  with cascade  impactor precollector.
                                       233

-------
                          CYCLONE
INLET
                           CYCLONE
               Figure  17.  Fugitive Assessment Sampling Train components.

-------
Figure 18.   Horizontal elutriator container for FAST.
                        235

-------
Figure 19.   Horizontal elutriator positioned downstream of inlet transform.
                               236

-------
Figure 20.   Slide covers protecting FAST horizontal elutriator.
                          237

-------
Figure 21.   Slide covers of FAST horizontal elutriator partially removed.
                                 233

-------

Figure 22.  Horizontal elutriator positioned on inlet of FAST.
                            230

-------
Figure 23.  Louvered inlet positioned on front of FAST.
                       240

-------
Figure 24,   Laboratory set-up  for calibration of FAST horizontal elutriator.
                                241

-------
u
z
L.I
u
u
LV
LU
Z

u
:
t
                                                       Pffl
                   RECTANGULAR
                 - CYLINDRICAL
       1.0        2.0         4.0    6.0   8.0 10         20         40    60   80 100

                        GEOMETRIC MEAN DIAMETER, micrometers
                                                                          4181-234

     Figure 25.   Laboratory calibration data for the  FAST horizontal elutriator inlet
                 collector.   Also shown are theoretical collection efficiency curves for
                 rectangular and cylindrical tubes.
                                    242

-------
                      TECHNIQUES FOR EVALUATING SURFACE AND
                    GROUND WATER EFFECTS OF DRY ASH DISPOSAL
                                       by
                      James F. Villaume, Project Scientist
                       Pennsylvania Power & Light Company
                             Two North Ninth Street
                                  Allentown, PA

                      Dennis F. Unites, Principal Scientist
                       TRC Environmental Consultants, Inc.
                             125 Silas Deane Highway
                                Wethersfield, CT
                                   ABSTRACT

Utilities are finding it necessary to switch to dry fly ash handling to
minimize water quality impacts.  At the same time, regulations regarding
solid waste disposal are becoming increasingly more stringent.  In
switching from a wet sluiced system to dry ash disposal at the Montour
Steam Electric Station, Pennsylvania Power and Light Company required
data as to the surface and ground water effects of ash disposal for both
design and permit purposes.  To provide these a study program of labora-
tory testing and computer modeling was conducted in conjunction with a
detailed site investigation.

Three types of laboratory testing were involved.  They included:  an
extraction leachate test to assess ash variability; a serial batchwise
extraction test to determine ash leachate quality and potential ground
water effects; and a runoff simulation.  To determine runoff quality the
simulation results were then used as input into a modified version of
EPA's SSWMM computer model.

The paper will discuss the testing techniques and how the program results
were incorporated into the disposal site design and plan of operations.

-------
                                   INTRODUCTION
 Pennsylvania  Power  &  Light  Company  (PP&L)  operates  a 1500-megawatt  coal-
 fired  (eastern  bituminous)  steam electric  generating station  (the Montour
 Station) near Washingtonville, Montour  County,  Pennsylvania.   In 1976
 PP&L was cited  by the state environmental  agency  for discharging arsenic
 at  levels which caused the  water quality criteria of the  station's
 receiving stream to be exceeded.  An  investigation  by the company revealed
 that most of  the arsenic was being  released  from  the fly  ash  as a result
 of  the wet  sluicing and ponding  process.   Attempts  to identify the
 mechanisms  controlling the  arsenic  levels  in the  ash pond were largely
 unsuccessful, and so  after  evaluating various other  alternatives (waste
 recycle, discharge relocation, and  stream  augmentation) the company
 decided to  convert the existing  wet ash handling  system to a  dry system.

 This meant  that  any ash which could not be immediately marketed for
 reuse would have to be landfilled.  After  considering twelve  possible
 sites, a 170-acre company-owned  tract adjacent,  to the station was finally
 selected as having the least potential environmental  impact after develop-
 ment (Figure  1).  To  determine just what this impact  would be and how
 best to minimize it,  a study of  the ash and  site  characteristics was
 undertaken.   Of  greatest concern were the  effects the ash leachate and
 runoff might  have on  local  ground water supplies and  area streams.   What
was being sought ultimately was  a basic landfill design concept and plan
of operations.
                                      244-

-------
  FIGURE  1
PLOT PLAN
      245

-------
                                   STUDY PROGRAM
                                  Ash Variability
 The variation in ash chemistry was investigated for two reasons.   First,
 the full range of chemical variability had to  be established so  that
 representative samples of  the ash could be collected for the later
 leaching and  runoff  simulations.   It  was also  necessary to  know  just  how
 this range fit into  the possibly  larger range  of ash types  likely  to  be
 produced by the station over  time,  so that the results  of the present
 study would have some applicability beyond just the immediate situation.
 Several  likely sources of  variation were considered.

 Generally speaking,  fly ash represents the non-combustible  fraction of
 the coal being burned.   Thus,  the chemical characteristics  of the  fly
 ash are  largely determined by the composition  of this non-combustible
 fraction,  which can  vary from coal  to coal,  even for coals  from  the same
 mine (1).   The Montour Station receives the  majority of  its coal from
 two supplies  in western Pennsylvania,  one  a  captive deep mine working a
 single seam ("Greenwich" coal)  and  the other a stripping operation
 working  up to five separate seams ("Benjamin"  coal).  The proportion  of
 coal coming from each is about 2:1  Greenwich:Benjamin.   To  the extent
 possible the  fly ash samples  collected for the study were keyed  to these
 two supplies  in an attempt to  control this one important source of
 chemical variation.

 Once in  the boiler,  where  the  fly ash is actually formed, the coal is
 subjected  to  various operating conditions  which  could also  contribute to
 ash variability.  They  include combustion  temperature, excess  oxygen,
 and station load.  Rather  than try  to  isolate  each  source of  variation,
 the extent  to  which  these  operating conditions might be  expected to
 change was  quickly checked  by  reviewing past station operating records.
 In  no case  was  the change  found to be  significant enough to warrant
 further  detailed  investigation.

After its  production in  the boiler, the fly  ash  is  exhausted  through  the
 station's  electrostatic  precipitators, where it  is  removed  from the
 combustion  gases  and  then  transferred  to a series of hoppers  for collec-
 tion  (32 for each generating unit arranged in  two banks  of  16, as  shown
in Figure  2).   From work done  earlier  at the station it was known  that
the smaller ash particles  tended  to be concentrated in the  outlet hoppers
 (those furthest from  the boiler) and  the larger  size fraction  in the
inlet hoppers  (those  closest to the boiler).   Since the  partitioning of
chemical elements by  ash particle size is well documented in  the litera-
ture  (2,  3, 4, 5), most of  the effort  to quantify the chemical variability
of  the ash was concentrated in this area.

The principal  technique used to evaluate the effects of  size  sorting on
ash chemistry was to  take a sample of  ash  from an inlet, outlet,  or mid-
range hopper, add it  to distilled water at a low solid:liquid ratio (50


                                       246

-------
  OUT
                                                                                      IN
STflCK
BOILER
  OUT
                                          B-4
                                                                                      IN
                                        FIGURE 2
                                 FLY ASH  HOPPER  LflYOUT

-------
 g:800 ml), mix for 10 minutes, let the mixture stand for an hour, and
 then decant and filter.  The parameters were standardized for each test
 run so as not to introduce any new variables into the system.  The
 mixing time selected was determined by separate test and represents a
 stable condition characterized by constant pH and conductivity.  The low
 solid:liquid ratio was designed to prevent suppression of one dissolved
 species by another more soluble species ("first ion effect").  The
 results of the analyses performed on the resulting solutions are presented
 in Tables 1 and 2.   As a gross check on these results samples of the ash
 itself were also analyzed by atomic absorption and emission spectrographic
 methods.   The results of these analyses are presented in Table 3.

 This data clearly shows that the Greenwich and Benjamin ashes produce
 very different aqueous solutions.   In particular,  the Greenwich ashes
 are generally strongly alkaline (pH 10-11), have a high calcium:iron
 ratio (characteristic of the strong alkalinity (6)),  and contain no
 detectable manganese or nickel.   The Benjamin ashes,  on the other hand,
 are strongly acidic (pH 3-4) and have a- low calcium:iron ratio.   This
 large difference in pH is significant because it indicates that any
 future changes in ash chemistry will probably fall within the range of
 characteristics already studied.

 The data  also shows a marked variation in  ash chemistry with particle
 size sorting,  as evidenced particularly by the increasing concentrations
 of  arsenic,  selenium,  and chromium in the  extracts from the hopper
 samples collected at increasing  distances  from the boiler.   Thus,  ash
 samples from the outlet hoppers  could be expected  to  produce "worst
 case"  solutions having the highest dissolved  metals concentrations.
 This was  important  to  know as far  as  planning future  sampling  activities.
 The data  from the first phase of  the  study also  served  to identify which
 chemical  elements would most likely be leached out of the ash  in  large
 amounts (the potential "bad actors")  and which in  insignificant amounts.
 For example,  cadmium and mercury were present in such low concentrations
 in  all of the  extracts that they were judged  not to be worth looking  at
 in  the following leaching and runoff  simulations.  Antimony  and lead,
 meanwhile, were  never  found in any of the  extracts, even  though the
 levels of lead in all  of the  whole ash samples were quite high (70-100
 mg/kg).

 An  interesting result  of the  variability data is the  comparison of  the
 recent ash samples with  those collected  in  1976, before  the  flue  gas
 conditioning systems (S0_  injection) were installed.  The largest dif-
 ferences  appear  to be  in the  Benjamin ash.  The older samples  produce
much lower concentrations  of  extractable arsenic and  selenium  and much
higher concentrations  of manganese, iron, nickel,  and zinc and they have
a much lower calcium:iron  ratio.   The  results from the whole ash analyses
                                     248

-------
                                                                       TABLE  1

                                                          RESUITS OF  ASH VARIABILITY TESTS
                                                            LEACHABLE CONSTITUENTS  (ug/g)
Hopper
A-l
A-4
A- 8
A-9
A-12
A- 16
A-l
A-4
A-8
A-9
A-12
A-16
A-l
A-4
A-8
A-9
A-12
A-16
2-B Inlet
2-B Inlet
2-B Inlet
2-B Inlet
2-B Inlet
2-B Inlet
B-l
Coal Type
Unit 112 Greenwich
"
11
11
"

Unit #2 Benjamin
"
"
"
11
ti
Unit #2 Greenwich
it
ii
"
"

Greenwich
Benjamin
Benjamin
Greenwich
Banjamin
Benjamin
Unit *2 Greenwich
Date
4/20/79
ft
It
II
It
II
4/19/79
11
ii
"
M
ii
6/08/79
It
"
lr
II
(1
5/14/76
5/06/76
5/05/76
5/13/76
12/07/76
12/15/76
7/06/79
As
4.0
2.4
2.9
2.7
3.5
2.7
7.4
4.3
1.1
4.2
3.7
7.8
3.4
3.0
3.8
3.7
5.1
3.5
2.5
0.8
0.85
2.0
0.03
0.11
2.2
Se
4.0
1.8
1.12
—
—
—
0.32
4.6
2.2
—
—
—
3.7
4.2
3.5
—
—
—
1.12
nd
nd
1.6
nd
nd
2.24
Sb
	
—
—
—
—
—
nd
—
—
—
—
—
__
—
—
—
—
— •
nd
nd
nd
nd
nd
nd
nd
Mo
	
—
—
—
—
—
4.3
—
—
—
—
—
__
—
—
—
—
—
11.2
nd
nd
9.6
nd
nd
31.2
B F
	 	
—
—
—
—
— —
14.9 14.7
—
—
—
— —
— —
_.
—
—
—
—
— —
3.2 38.7
3.2 81.6
7.2 35.2
9.6 26.4
nd 3.0
8.8 51.2
7.2 5.3
Al
333.
151.
102.
250.
192.
78.6
176.
261.
282.
73.1
12.2
230.
370.
293.
317.
782.
198.
140.
349.
414.
285.
126.
261.
576.
237.
Mn
nd
nd
nd
nd
nd
nd
4.5
nd
nd
0.5
0.8
nd
nd
nd
nd
nd
nd
nd
nd
22.2
25.1
nd
52.0
30.6
nd
Fe
nd
i.n
nd
1.6
nd
] .0
8.6
1 .1
1.0
nd
2.6
nd
1.8
nd
nd
2.1
nd
nd
nd
86.4
88.8
nd
138.
59.2
nd
Ca
4,336.
4,360.
4.8SO.
2.6S8.
2,304.
2,6'2.
2,656.
2,1«4.
3,008.
2,192.
2,000.
1,632.
2,720.
3,008.
2,800.
2,240.
2,096.
1,920.
1,512.
717.
1,096.
1,808.
653.
2,080.
1,664.
Total Cr
3.7
2.4
nd
—
—
—
2.2
nd
nd
—
—
—
1.9
nd
nd
—
—
—
nd
3.8
nd
nd
nd
nd
1 .6
Zn
1.7
4.5
0.32
—
—
—
10.4
0.2
0.3
—
—
—
__
0.3
0.2
—
—
—
0.64
99.2
191 .
0.48
501.
87.2
0.48
Ni
nd
nd
nd
—
—
—
7.7
—
—
—
—
—
nd
nd
nd
—
—
—
nd
31.8
35.4
nd
302.
62.4
nd
Cd
nd
nd
nd
nd
nd
nd
0.5
—
—
—
—
—
nd
nd
nd
nd
nd
nd
	
—
—
—
—
—
~~~
Pb
nd
nd
nd
—
—
—
nd
nd
nd
—
—
—
nd
nd
nd
—
—
—
	
—
—
—
—
—

Hg
nd
nd
0.006
—
—
—
	
—
—
—
—
—
nd
nd
nd
—
—
—
	
—
—
—
—
—
™
NOTES :
"nd" indicates none detected.

-------
                                                             TABLE 2



                                            SELECTED pH, CONDUCTIVITY, AND TDS  RESULTS

                                                   FROM ASH VARIABILITY TESTS
to
ui
o
GREENWICH
Unit 2
Hopper it
A-l
A-4
A-8
A- 9
A-12
A-16
B-l
B-8
B-9
B-12
B-16
A-l
A-4
A-8
A-9
A-12
A-16
B-l
B-4
B-8
B-9
B-12
B-16
Date
4/20/79
It
tt
ft
If
ft
ft
IT
II
tt
6/08/79
tl
II
If
tt
II
tt
tt
M
It
It
If
10.2
11.3
11.4
11.0
11.2
11.6
10.3
11.2
11.0
11.1
10.9
10.3
10.1
10.4
10.2
10.6
10.7
10.3
11.2
10.2
10.5
10.6
10.4
Conductivity
(uMHO)
1496
2095
2645
1277
1127
2095
1496
1195
1417
1187
1602
1101
1251
1216
1031
887
953
1197
1100
1050
964
914
844
TDS
(mg/L)
1482
854
1199
1021
809
795
1360
1014
858
783
724
982
1207
1056
933
682
568
1163
935
920
823
795
651
Date
4/19/80
IT
II
IT
It
II
II
It
||
6/21/79
6/21/79
—
6/21/79
6/21/79
—
BENJAMIN
Conductivity
pH (uMHO)
4.1
9.9
8.8
8.6
7.4
10.4
4.0
5.2
4.7
4.3
8.1
3.9
3.7
—
3.7
3.9
—
1376
886
1367
917
877
707
1338
1308
988
958
808
1100
1400
—
1150
1100
—

TDS
(mg/L)
1320
748
1292
775
727
567
1272
1195
844
1267
648
936
1446
—
1126
948
—

-------
                  TABLE 3

RESULTS OF WHOLE ASH ATOMIC ABSORPTION AND
     EMISSION SPECTROGRAPHIC ANALYSIS
A1203
Fe203
CaO
MnO
As
Cd
Pb
Se

Fe203
CaO
MnO
As
Cd
Pb
Se
Benj amin
Inlet
Composite
6-21-79
25.6%
13.1%
2.08%
0.033
440ppm
1.4
75
28
Benjamin
Inlet
5-6-76
26.6%
16.0
1.62
0.039
-290ppm
0.9
100
50
Greenwich
Composite
4-20-79
25.9
9.59
3.98
0.039
230
1.5
70
14
Greenwich
Inlet
5-13-76
25.1
8.22
2.67
0.046
130
1.2
70
21
Greenwich
Composite
6-8-79
26.0
9.60
3.15
0.036
190
1.6
80
16
Greenwich
Inlet
5-14-76
24.9
8.56
2.63
0.047
100
1.1
75
21
Benj amin
Composite
4-19-79
26.0
12.9
2.35
0.032
210
1.2
80
23
Benj amin
Inlet
12-2-76
26.2
15.2
1.38
0.050
150
1.2
80
70
Benj amin
Composite
5-5-76
26.2
17.1
1.72
0.036
280
1.1
80
45
Benj amin
Inlet
12-15-76
26.4
15.4
1.60
0.045
300
1.0
90
44
                    251

-------
confirm these differences.  While this change in ash chemistry cannot be
attributed to an exact cause, it is worth noting because it shows the
magnitude of the changes which are possible from factors other than
simple size sorting and chemical conditioning.
                                    252

-------
                              Leaching Simulations
Leaching is the process whereby certain constituents of the ash become
dissolved in water as it percolates downward through the ash pile.  This
process can be simulated in the laboratory—at a great expense of
time—by packing columns with the ash and then allowing water to pass
through them.  A quicker way, and one which has been shown to produce
comparable results (7), is to mix the ash with water at a high solid:
liquid ratio.  To find out what is happening at a given level in the ash
pile over time, "batches" of water representing a certain pore volume
can be added to the ash and then extracted.  By knowing the flow velocity
through the ash under field conditions, the equivalent time of penetration
for each batch of water can be calculated.  A portion of each extract
can then also be used to challenge another type (layer) of ash or some
other material, such as a site soil.  This new extract would show how
the leachate changes as it moves through the pile.  The overall simulation
method just described is referred to as serial batchwise extraction.
The specific technique followed in the present study and the associated
equation for calculating equivalent time of penetration (leaching) are
discussed in detail by Houle and Long (7).

Using this method three scenarios representing three different field
conditions were simulated in the laboratory.  The first involved a
combination of Greenwich and Benjamin ashes from the outlet hoppers
("worst case" combination) overlying a typical site soil.  The second
involved the same combination of ashes overlying that combination again,
but after partial leaching, overlying bottom ash (coarse boiler slag).
The partially leached material was intended to represent ash which had
been exposed for a time on the pile (aged ash).  The bottom ash was
being evaluated as a possible drainage blanket material.  The third
scenario involved a combination of Benjamin ashes from across the hopper
series ("average" combination) overlying the aged Greenwich-Benjamin
ash combination overlying bottom ash again.  These three scenarios are
shown schematically in Figure 3.  The general extraction sequence is
shown in Figure 4.  The results of the analyses performed on the extracts
are presented in Tables 4 through 6.

The site soil was also subjected to the extraction procedure to determine
what constituents it might contribute to the leachate.  The extraction
sequence which was followed is the same as that shown in the first
column of Figure 4.  The analytical results are presented in Table 7.

Figure 5 illustrates how the data from the scenarios can be interpreted.
Similar graphs can be prepared for all of the analysis parameters.  What
this one example from Scenario 1 shows is that very little arsenic is
dissolved from the ash initially, apparently due to the greater solubility
of other constituents, such as sulfate, which actually control the
solubility of the arsenic.  Selenium and chromium follow the same general


                                      253

-------
SCENARIO  I
  'HORST-CASE'
 COMBINATION OF
FRESH GREENNICH
A BENJAMIN ASHES
  3 SUCCESSIVE
   BATCHES OF
   'SITE SOIL'
SCENARIO  II
  'HORST-CASE'
 COMBINATION OF
 FRESH GREENNICH
 A BENJAMIN ASHES
   'HORST-CASE'
 COMBINATION OF
 AGED GREENWICH A
 BENJAMIN ASHES
                                         BOTTOM ASH
                                          DRAINAGE
                                           BLANKET
 SCENARIO  III
'AVERAGE' COMBINATION
     OF FRESH
   BENJAMIN ASHES
     BOTTOM ASH
      DRAINAGE
      BLANKET
                                                                                   I
                                        FIGURE  3
                                 SCENARIO SCHEMATIC

-------
                                                                                       FILTRATE
N5
U>
Ol
HATER
HATER
HATER

ASH
i
FILTRATE
SOIL
BATCH I
1
S-A1-1
FII TRATF
FILTER
CAKE

FILTRATE
FILTRATE
SOIL
BATCH II
1
S-B1-1
FILTRATF '
FILTER
CAKE
1
S-A1-2
FTI TRATF
FILTER
CAKE
FILTRATE
1
FILTRATE
	 »•
FILTRATE
SOIL
3ATCH III
1
S-C1-1
FII TRATF
FILTER
CAKE
\
S-B1-2
FILTRATF
FILTER
CAKE
FILTRATE
1
FILTRATE

FILTER
CAKE
1
S-C1-2
FII TRATE
FILTER
CAKE
FILTRATE
i

FILTER
CAKE
FILTRATE
1
S-01-1
FILTRATE
1
S-01-2
FILTRATE
1
                                         S-A1-3
                                         S-A1-4
                                         S-A1-5
                                         S-A1-6
                                         S-A1-7
                                         S-A1-8
S-B1-3
 ETC.
S-C1-3
 ETC.
S-01-3
 ETC.
                                                              FIGURE 4
                                                   GENERAL  EXTRACTION SEQUENCE

-------
to
Ln
                                                                                  TABLE 4

                                                                                SCENARIO 1
                                                                      EXTRACTABLE CONSTITUENTS (ug/g)

Sample Nuuber

New Fly Ash
S1-A1
S1-A2
SI -A3
S1-A4
S1-A5
S1-A6
S1-A7
S1-A8
Sice Soil Batch 1
S1-B1
S1-B2
S1-B3
S1-B4
S1-B5
S1-B6
S1-B7
S1-B8
Site Soil Batch 11
01 JM
3X^^*1.
S1-C2
S1-C3
S1-C4
S1-C5
S1-C6
S1-C7
S1-C8
Site Soil Batch III
Sl-01
S1-D2
S1-D3
S1-D4
S1-D5
S1-D6
S1-D7
S1-D8

As


0.048
0.67
1.29
3.5
22.5
24.0
40.1
22.7

nd
nd
0.072
0.17
2.04
29.8
35.5
24.0

On&
. UH
nd
0.03
0.04
0.38
9.8
25.3
24.2

nd
—
nd
nd
0.17
—
—
~

Se


0.68
0.5
0.70
2.58
1.92
nd
0.29
nd

nd
0.054
0.06
0.12
nd
1.44
nd
(7.7)

n 09?
U • \j£.£.
0.03
nd
nd

—
—
—

nd
—
nd
nd
—
—
—
—

Sb


nd
nd
nd
nd
—
—
—
—

nd
nd
—
nd
—
—
—
—


nd
—
nd
—
—
—
—

nd
—
—
nd
—
—
—
—

Mo


46.6
12.0
3.42
1.8
nd
nd
nd
nd

6.84
9.3
9.0
7.2
20.2
(67.2)
nd
(67.2)


4.8
17.1
33.6
—
—
—
—

nd
—
15.0
52.8
12.0
—
—
—

B


5.0
1.35
nd
4.8
nd
nd
nd
(18. 4)

4.2
1.05
2.7
3.6
nd
—
—
nd


1.86
nd
5.4
nd
—
—
—

1.16
—
2.4
nd
nd
—
—
—

F


1.62
0.6
1.62
10.9
13.0
5.76
4.8
5.76

1.5
1.23
4.08
17.5
—
—
—
—


1.86
3.78
12.1
31.4
—
__
—

1.4
—
4.08
9.36
31.9
—
—
—

AI


48.6
30.0
49.0
250.0
	
—
—
—

nd
nd
—
nd
—
—
—
—


nd
nd
—
—
—
—
—

nd
—
—
nd
—
—
—
~

Hn


nd
nd
nd
nd
nd
nd
nd
nd

0.68
0.57
0.54
nd
—
—
—
—

OCA
. 7*4
0.78
nd
nd
nd
—
--
—

0.54
—
nd
nd
nd
—
—
~

Fe


nd
0.42
0.72
1.32
__
—
—
—

nd
nd
—
nd
—
—
—
—

A T
u . /
nd
nd
—
—
—
—
—

nd
—
—
nd
—
—
—
~

Ca


500
372
431
598
955
979
1085
(8448)

504
348
597
521
1764
1334
(6144)
(15360)


1296
756
1019
—
—
—
—

328
—
1512
2052
2098
—
—
—
Total
Cr


0.5
nd
nd
nd
nd
nd
nd
nd

1.48
0.84
nd
nd
nd
nd
nd
nd

\ 7ft
J . £o
1.74
nd
nd
—
—
—
—

2.82
—
2.46
nd
nd
nd
—
—

Zn


0.14
0.24
0.18
0.24
0.48
nd
nd
nd

0.14
nd
nd
nd
—
—
—
—

n 7R
t > . <1O
0.21
nd
1.8
—
—
—
—

0.18
—
0.3
nd
nd
—
—
—

Ni


nd
nd
nd
nd
—
—
nd
—

nd
—
—
nd
—
—
—
—

r»H
nQ
nd
nd
nd
—
—
—
—

nd
—
—
nd
—
—
—
—

S°4


3550
4530
5160
1596
864
96
96
192

3150
5100
5400
1956
—
—
—
—


4305
6300
—
—
—
—
—

3150
—
5550
—
—
—
—
—

pH


10.3
10.2
10.0
10.5
9.8
9.2
8.9
8.1

7.5
7.5
7.8
8.2
8.4
8.1
7.8
7.5

7 J
1 * £.
7.2
7.2
7.3
7.4
7.5
7.5
7.4

7.3
7.2
7.2
7.1
7.3
7.3
7.3
7.4

IDS


5620
7350
8916
4788
3038
2702
3302
3821

—
—
—
—
—
—
—
—


—
—
—
—
—
—
—

—
4.6
—
—
—
—
—
—
Equiva lent
Days of
Penetration

1.8
4.6
10.1
21.2
43.2
87.4
175.7
352.4

1.22 Yr
3.04
6.7
13.9
28.6
57.8
116.2
233

1 7"? YT
-L i Z Z if
3.04
6.7
13.9
28.6
57.8
116.2
233

1.22 Yr
3.04
6.7
13.9
28.6
57.8
116.2
233
          NOTES:

          Scenario 1 involves a combination of fresh Greenwich and Benjs
          "nd" Indicates none detected.
          "O" indicate a possible "outlier" value.
tin  fly ashes  from  hoppers A-l  and  B-l  In  direct  contact  with site  .soil.

-------
                                                                  TABLE 5

                                                                SCENARIO 2
                                                      EXTRACTABLE CONSTITUENTS (ug/g)
N>
Sample
Number

New Fly Ash
S2-A1
S2-A2
S2-A3
S2-A4
S2-A5
S2-A6
S2-A7
S2-A8
Aged Fly Ash
S2-B1
S2-B2
S2-B3
S2-B4
S2-B5
S2-B6
S2-B7
S2-B8
Bottom Ash
S2-C1
S2-C2
S2-C3
S2-C4
S2-C5
S2-C6
S2-C7
S2-C8

As


0.072
0.24
0.70
3.34
8.62
23.7
39.8
30.3

0.68 '
0.73
1.07
3.66
11.0
36.6
73.2
77.6

nd
nd
0.23
0.17
7.27
33.4
73.2
86.0

Se


0.58
0.54
0.60
nd
1.68
1.92
0.96
nd

0.14
0.03
0.36
1.56
2.88
2.88
3.84
nd

nd
nd
nd
nd
0.65
1.44
3.84
nd

Sb


nd
nd
nd
nd
nd
nd
nd
nd

nd
nd
nd
nd
nd
nd
nd
nd

nd
nd
nd
nd
nd
nd
nd
nd

Mo


39.
9.54
3.78
1.8
2.64
nd
nd
15.36

39.
8.34
3.3
2.76
(28.8)
3.84
7.68
15.36

0.76
0.36
6.27
11.4
3.6
3.84
nd
nd

B


4.32
nd
nd
nd
nd
nd
nd
nd

3.42
nd
—
nd
nd
nd
nd
nd

4.24
4.53
2.64
nd
nd
(21.12)
nd
nd

F


—
—
—
—
—
—
—
—

—
—
—
—
—
—
—
—

nd
0.93
1.20
11.88
13.68
17.28
15.36
11.52

Al


43.6
72.
95.6
99.7
—
—
—
—

9.8
24.0
72.
168.
—
—
—
—

nd
9.8
12.8
60.2
—
—
—
—

Mn


nd
nd
nd
nd
—
—
—
—

nd
nd
nd
nd
—
—
—
—

14.
1.
0.
nd
—
—
—
—

Ca


308
732
1278
594
725
266
(4512)
1674

600
426
1734
525
1397
2150
3936
(10330)

0 36
11 1116
48 1908
802
1488
3034
(6192)
(12000)

SO^


1720
5370
5040
606
—
—
—
—

3280
4440
5760
1392
—
—
—
—

5024
5160
7680
2076
—
—
—
—

pH


9.9
10.2
10.0
9.8
9.6
9.3
7.9
7.1

9.2
9.3
9.2
10.0
9.8
8.9
8.6
8.4

3.0
4.6
7.8
8.7
9.0
8.6
8.5
7.3

TDS


5260
7350
8220
1740
2388
2981
2707
(10330)

—
—
8880
3492
3936
3989
5741
5779

—
—
8340
3420
3888
3744
5453
6278
Equivalent
Days of
Penetration

1.8
4.6
10.1
21.2
43.2
87.4
175.7
352.4

1.8
4.6
10.1
21.2
43.2
87.4
175.7
352.4

0.005
0.013
0.03
0.06
0.12
0.25
0.5
1.0
NOTES :
        Scenario 2 involves a combination of  fresh Greenwich and Benjamin fly ashes from hoppers A-l and B-l challenging a combination
        of "aged" Greenwich and Benjamin fly  .ashes and bottom ash.
        "nd" indicates none detected.
        "()" indicate a possible "outlier" value.

-------
                                                                  TABLE 6

                                                                SCENARIO 3
                                                      EXTRACTABLE CONSTITUENTS (ug/g)
to
m
00
Sample
Number

New Fly Ash
S3-A1
S3-A2
S3-A3
S3-A4
S3-A5
S3-A6
S3-A7
S3-A8
Aged Fly Ash
S3-B1
S3-B2
S3-B3
S3-B4
S3-B5
S3-B6
S3-B7
S3-B8
Bottom Ash
S3-C1
S3-C2
S3-C3
S3-C4
S3-C5
S3-C6
S3-C7
S3-C8

As


0.26
0.48
0.78
5.52
18.0
26.9
127.
21.1

0.86
1.26
1.56
3.84
16.8
49
57.6
3.84

0.06
0.01
0.06
0.24
3.6
39.8
70.0
57.6

Se


0.58
0.48
0.69
1.72
0.34
0.16
0.10
nd

0.15
0.08
0.91
0.95
2.42
0.10
0.23
0.33

nd
nd
0.02
0.01
0.89
0.72
1.44
1.11

Mo


28.0
4.8
1.14
nd
—
—
—
—

20.6
7.7
2.1
nd
—
—
—
—

1.54
nd
3.5
8.5
—
—
—
—

B


5.84
nd
—
—
—
—
—
—

4.22
3.6
rd
nd
--
--
—
—

4.32
3.18
nd
nd
—
—
—
—

F


7.50
3.45
5.46
6.72
4.80
3.36
4.80
5.76

0.68
0.90
4.50
10.56
—
—
—
—

4.0
1.02
2.88
16.20
—
—
—
—

Mn


nd
—
—
—
—
nd
(3.84)
nd

nd
—
—
—
—
—
—
—

15.62
1.08
nd
nd
—
—
—
—
Total
Cr


0.18
nd
nd
nd
nd
nd
nd
nd

0.72
0.39
nd
nd
nd
nd
nd
nd

1.14
nd
nd
nd
nd
nd
nd
nd

Ni


nd
nd
nd
nd
nd
nd
(13.4)
nd

nd
—
—
—
—
—
—
—

162.5
22.6
0.66
nd
—
—
—
—

S°4


3820
4620
1170
415
214
86.4
355
384

—
—
2340
900
797
749
643
288

—
—
3870
1158
1104
739
739
384

PH


9.7
10.1
10.1
9.9
9.2
8.8
7.8
7.2

9.6
9.1
9.4
10.2
9.8
9.3
90
S.9

3.1
3.7
8.2
8.7
9.0
8.9
8.5
7.6

TDS


5798
6519
2550
1632
1226
1094
3168
6624

—
—
3798
2808
3120
3811
4848
6624

—
—
5172
2532
2784
3758
3514
6451
Equivalent
Days of
Penetration

1.8
4.6
10.1
21.2
43.2
87.4
175.7
352.4

1.8
4.6
10.1
21.2
43.2
87.4
175.7
352.4

0.005
0.013
0.03
0.06
0.12
0.25
0.50
1.0
NOTES:
        Scenario 3 involves a combination of fresh Benjamin fly ashes from hoppers A-4, A-8, A-9, A-12, A-16, B-8, B-9, B-12, and B-16
             challenging a combination of "aged" Greenwich and Benjamin fly ashes and bottom ash (same as in Scenario 2).
        "nd" indicates non detected.
        "()" indicates a possible "outlier" value.

-------
                                                         TABLE 7

                                                  SITE SOIL EXTRACTIONS
                                             EXTRACTABLE CONSTITUENTS (ug/g)



N5
Ul
VO
Sample Total Total
Number As Se Sb Mo B F Al Mn Fe Ca Cr Zn Ni C SO^ pH TDS
SX-1 0.012 0.008 nd 0.44 1.26 1.6 nd 0.2 nd 156. 1.48 (1.12 nd 30 670 7.1 1402
SX-2 0.018 nd nd 1.32 nd 3.75 nd nd nd 52.8 1.23 nd nd 39 153 7.4 486
SX-3 0.072 nd nd 3.48 nd 7.32 10.2 nd 1.62 232. 0.78 0.36 nd 42 60 7.6 2292
SX-4 0.108 .nd nd 8.4 5.4 11.3 nd nd nd 30.6 nd nd nd 72 12 7.7 2200
NOTES :
Equivalent
Days of
Penetration
1.22
3.04
6.7
13.9

SX-1 indicates the first site soil extraction, etc.
"nd" indicates none detected.

-------
ON
O
               ASH
          5^120
             no
             100
                                            EQUIVALENT DAYS PENETRATION
                                                   THROUGH ASH
                                                          FIGURE 5
                                               INTERPRETATION OF SCENARIO  1
                                                        ARSENIC DATA

-------
 release  pattern.  After  about  three  simulated months  of  leaching  the
 concentrations  of the  metal  in solution  increase  dramatically  as  the
 more soluble constituents  are  removed  from  the  system.   This increase
 continues  for a while  and  then the concentrations begin  to  slowly decline.
 In  the soil  the arsenic  is retained  at first, but then it passes  through
 without  appreciable  attenuation.

 Another  interesting  aspect of  the results is presented by the  pH  data.
 In  the variability tests the pH values ranged between 4  and 11 for  the
 Benjamin and Greenwich ashes,  respectively, while in  the batchwise
 extractions  they never got below 7 after one simulated year of leaching.
 This shows the  value of  not  relying  exclusively on a  simple "shaker"
 type of  test to determine  the  leaching characteristics of a solid waste.

 Since the  serial batchwise extractions were carried out  under  essentially
 equilibrium  conditions (the  reaction vessel was stirred  until  the time
 rate of  change  of pH and conductivity  reached zero) and  at a constant
 solid:liquid ratio,  a  question remained as  to what the very first leachate
 generated  at the moving  front  of the wetting mass would  look like.  To
 answer this  question a separate series of extractions (wetting front
 tests) was performed on  the  worst-case Greenwich  and  Benjamin  ash combin-
 ation and  on the average Benjamin combination.  Basically, what was done
 was  to add fresh ash to  each successive extract to determine maximum
 solubilities of  the  various  constituents of interest; however, mixing
 times did  not exceed 30  minutes, compared to two  hours for the batchwise
 extractions.  The extraction sequence  is shown by the top row  of  Figure
 4 and the  analytical results are given in Table 8.  Generally,  this data
 served to verify the concentration ranges already established  in  the
 variability  tests and  scenarios, except that the  pH values tended to be
 very low (in the range of  about 3 to 4).  This was probably due to  the
 short mixing times involved, which apparently favor the  release of  early
 acid-producing  constituents  from the ash.

 Using these  ranges,  which  are  summarized in Table 9,  it  was then  possible
 to determine the concentrations of certain pollutants likely to appear
 in the leachate  at the bottom  of the landfill.  This  was done  by  assuming
 that  2-5% of  all the precipitation which falls on the ash will infiltrate
 it (these are laboratory values, although they have also been  verified
by actual field  experience).   By knowing the volume of water which
 infiltrates  the  ash  pile (about 20,000 gal/yr per  5-acre segment  based
on an annual  precipitation for  the site of about  43 inches and a  2%
 infiltration rate) and the pounds of extractable  constituents  per ton of
ash, the concentrations  of those constituents in  the  leachate  can then
be calculated for different  stages of  development  of  the landfill.  The
results  of these calculations  are given in Table  10 for  arsenic,  selenium,
and  sulfate,  which when  compared to  the EPA's primary (health  based)
                                     261

-------
                                    TABLE 8

                           WETTING FRONT TEST //I
                      EXTRACTABLE CONSTITUENTS (ug/g)
Sample
Number
Wl-1
Wl-2
Wl-
3
As
0.74
1.22
2.44
Se
nd
nd
nd
*
Mo
0.16
0.34
0.7
B F
13.2 1.22
25.2 0.2
39.2 0.18
Al
39.4
252.
398.
Mn
5
11
18
.08
.9
.4
Ca
408
564
298
TDS
6646
9348
13372
NOTES:
 This  test  involved  a combination of  fresh Greenwich  and  Benjamin  fly  ashes
    from hoppers A-l and  B-l.
 "nd"  indicates  none detected.
                          WETTING FRONT TEST #2
                     EXTRACTABLE CONSTITUENTS  (ug/g)
Sample Number
W2-1
W2-2
W2-3
W2-4
As
0.18
0.8
0.76
0.5
Mo
9.64
0.34
0.86
2.9
B
7.82
14.96
25.0
27.2
F
1.26
0.2
9.1
0.72
Mn
0.74
4.34
5.86
5.96
TDS
5766
6398
7408
7946
NOTE:
This
 test involved a combination of fresh Benjamin fly ash from hoppers A-4
V-8,  A-9,  A-12,  A-16,  B-8,  B-9, B-12 and B-16.
                                      262

-------
                                        TABLE 9

               AVERAGE AND MAXIMUM CONCENTRATIONS OF CONSTITUENTS APPEARING AT
               THE BOTTOM OF INDIVIDUAL LAYERS IN SCENARIOS 1,  2, AND 3 (ug/g)
                                Scenario 1
Scenario 2
                                                                          Scenario  3
Parameter
As
Se
Sb
Mo
B
F
Al
Mn
Fe
Ca
Cr (Total)
Zn
Ni
SO,
TDS
Concentration
Avg.
Max .
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Avg.
Max.
Ash
14.4
40.1
1.11
2.58
nd
16.0
46.6
3.72
4.8
5.51
13.0
94.4
250.
nd
0.82
1.32
703.
1085.
0.5
0.5
0.26
0.48
nd
2011.
5160.
4942.
8916.
Soil
0.04
0.17
nd
nd
19.9
52.8
0.89
2.4
11.7
31.9
nd
0.13
0.54
nd
1498.
2098.
1.06
2.82
0.12
0.3
nd
4350.
5550.
na
Fly Ash
25.6
77.6
1.67
3.84
nd
11.5
15.4
3.42
3.42
nd
68.5
168.
nd
na
1538.
3936.
na
na
na
3718.
5760.
5303.
8880.
Bottom Ash
25.0
86.0
0.74
3.84
nd
3.28
11.4
1.63
4.53
10.3
17.28
20.7
60.24
3.9
14.0
na
1397.
3034.
na
na
na
4984.
7680.
5187.
8340.
Fly Ash
16.8
57.6
0.05
2.42
na
10.1
20.6
3.91
4.22
4.16
10.56
na
nd
na
na
0.56
0.72
na
nd
853.
2340.
4168.
6624.
Bottom Ash
21.4
70.0
0.52
1.44
na
3.4
8.5
1.9
4.32
6.02
16.2
na
4.2
15.62
na
na
0.14
1.14
na
23.2
162.5
1332.
3870.
4035.
6451.
NOTES;

"Outliers" from Tables 4 through 6 were not used in calculations.
"nd" indicates none detected.
"na" indicates no analyses.
                                            263

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                                 TABLE 10

                   CALCULATED CONCENTRATIONS OF SELECTED
                          POLLUTANTS IN LEACHATE
Pollutant
Arsenic
Selenium
Sulfate
Maximum
Concentration
(mg/L)
0.83
0.04
1600
Average
Concentration
(mg/L)
0.25
0.01
135
EPA Drinking
Water Standard
Cmg/L)
0.05
0.01
250
NOTE:
Values are based on an average annual precipitation of 43 inches and 2%
infiltration rate into the ash pile.
                                      264

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drinking water standards appear to represent the .greatest potential
problem.  Interestingly, the Scenario 1 data also indicates that these
same constituents are not likely to be significantly attenuated by the
site soil, which suggests the need to intercept the leachate for possible
treatment or dilution with the other waste streams emanating from the
landfill, such as runoff.
                                     265

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                          Runoff Simulations and Modeling
 Stormwater runoff from the proposed landfill was simulated in the labora-
 tory by using a modification of a technique developed by IU Conversion
 Systems, Inc. (8).   The purpose of the simulations was to provide input
 to the computer model on runoff quality and flow.   The IUC technique
 basically involves  packing a metal box with the ash to approximate field
 conditions,  preparing the surface (rough,  smooth,  baked with a heat lamp
 to simulate  prolonged exposure to intense  sunlight,  and so on),  and then
 spraying reagent grade water over the surface.   The resulting runoff is
 caught and recirculated for one hour.  By  using a  constant flow rate
 over a known surface area, each simulation represents a one hour rainfall
 of a certain intensity running off a unit  area  of  ash.   The result is a
 family curves relating inches of rain to linear feet of runoff  for
 different application rates (storm intensities).   These curves  are
 presented in Figure 6.

 An average Greenwich and average Benjamin  ash (equal-volume grab samples
 from the inlet and  outlet hoppers)  were used  for the simulations.   pH
 and conductivity were monitored continously in  the recirculated  runoff.
 The average  pH of all the runoff water for both ash  types  was 6.0,
 although the Greenwich runoff had an average  pH of about 6.1 and the
 Benjamin Runoff  an  average pH of 5.8.   This contrasts with the drastically
 different pH values found for the two ash  types in the  variability
 tests.   During each simulation,  the initial runoff pH was  about  5.5  and
 then slowly  increased to neutral or slightly  above.   Conductivity  followed
 the same pattern, starting at about 40 umhos  and ending at about 800.
 The results  of the  analyses performed on the  final runoff  for the  other
 parameters of interest  are given in Table  11.   Generally,  they are
 consistent with  the results from the variability tests  and so do not
 deserve  further  discussion here.

 The computer model  selected for  the second phase of  the runoff analysis
 is  a modification of  EPA's Short Stormwater Management  Model  (SSWMM).
 The modification was  necessary  to allow consideration of the pollutants
 in  the runoff, rather than just  the  runoff  flow.   The model  addresses
 washoff,  surface detention,  depression storage, and  infiltration,  but
 does not  look at how  this  infiltration might  change  the runoff character-
 istics.   Instead, it  focuses  on  pollutant  transport  by  overland  flow and
 channel  routing  and the  exponential  decay  of pollutants  through washoff.

While the  runoff simulator was exposed  to  a constant  rate  and volume of
 precipitation, the model processed  storms with  varying  intensities and
 total precipitation amounts.  Five  storm events representing a broad
 range of storm types  were  selected for  analysis.  These storms are
characterized in Table 12.  Total precipitation values  for  the area were
obtained from U.S. Weather Bureau data  (9).  Published  statistical
hyetographs  for  10% and  50% probability storms were  used to show how

                                      266

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N)
C^
--J
                                        100
150
200
250
300
350
400
                                                    LINEftR FEET RUNOFF
                                                      6  INCHES HIDE
                                                       FIGURE 6
                                               SIMULATED FLOH-RUNOFF

-------
                                                 TABLE 11

                                  SELECTED RUNOFF SIMULATOR TEST RESULTS
Sample
Description


Source Hopper No.
Bearing Cap.
Thickness of
% Moisture
(tons/ft2)
Ash (in.)

Avg. Test Flow (gph)
Vol. of Water
Analyses:
Avg. pH
Avg. Cond.
TSS
TDS
Sett. Solids
to As
S Al
Ca
Fe

Cr

Ni
Se

Zn

B
F
Sb
Mo
Mn
so,
Retained (ml)


umho
mg/1
rag/1
mg/1
rag/1
rag/1
mg/1
mg/1

mg/1

mg/1
mg/1

mg/1

rag/1
mg/li.
mg/1
mg/i
mg/i
mg/1
Rough Compact
Benj amin
A1B1A8B8
1.25
6
20
11.9
1400

—
—
6564.
714.
—
.085 *
nd *
66.5 *
nd *
—
nd *
—
nc
nd *
—
0.08 *
—
0.75 *
0.22 *
nd *
0.91
0.05 *
493. *
Sun Dried
Benjamin
VlA8B8
1.41
6
20
15.2
1500

—
—
47864.
1076.
—
.100 *
nd *
58.5 *
nd *
—
nd *
—
nd
0.03
—
0.03 *
—
nd *
0.43 *
nd *
1.10 *
0.08 *
718. *
Compacted
Benjamin
AlBlV58
1.78
6
20
14.9
0

5.8
420
37568.
799.
38.38
6.19
399.
204.
nd *
114.
nd *
1.09
—
0.052*
0.14
0.04 *
2.34
questionable data
1.0
—
0.430
—
452.
Compacted
Greenwich
A1B1B8
3.69
4
20
16.7
100

6.0
458
40662.
1060.
78.78
0.66
36.2
475.
nd *
0.41
nd *
0.26
—
0 . 006
nd *
0.98
—
15.4
0.26
—
0.196
—
605.
Rough Compact
Greenwich
A1B1B8
1.25
4
20
17.8
0

6.6
240
24165.
556.
32.91
3.34
70.0
207.
—
12.1
—
0.80
—
0.019
—
0.65
—
19.6
0.27
—
0.313
—
252.
NOTES:

"*" indicates dissolved; otherwise, total.
"nd" indicates none detected.

-------
Storm Event

1-Year/30-Minute

1-Year/2-Hour

1-Year/6-Hour


l-Year/24-Hours

10-Year/24-Hours
               TABLE 12

CHARACTERISTICS OF MODELED STORM EVENTS


         Description

    Summer thunder shower

    Series of summer thunder showers

    Heavy rain preceding frontal
    passage (spring, fall)

    Moderate, steady rain

    Heavy, steady rain
Total Rainfall (in.)

          0.8

          1.3

          1.8


          2.3

          4.5
                                       269

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rainfall intensity varies with time for short- and long-duration storm
events, respectively.

The modified SSWMM model evaluated 13 pollutants; however, it could not
be calibrated independently for each.  As a result, only two pollutants,
arsenic and selenium, were selected as the focus of the calibration.
The model was calibrated to 0.1 milligrams for these two pollutants and
within one order of magnitude for sulfate, although it consistently
predicted total dissolved solids at much lower levels than the measured
values of 700-1400 milligrams per liter.

Figures 7 and 8 show how the concentrations of selected pollutants
change for the runoff from Greenwich ash during a short and long storm
event.  The curves for the Benjamin ash are very similar.  Also shown is
how the runoff flow changes.  Table 13 is a summary of the pollutant
concentrations in the total runoff, assuming all of it is collected.
Interestingly, these concentrations are not significantly different for
the two types of ash and do not vary at all with the storm event; however
the arsenic and selenium levels consistently exceed the EPA's primary
drinking water standards.  This again suggests the need for some sort of
treatment or flow combination.
                                    270.

-------
    200
i««  100 +
      Ot
                                     LEGEND
                                       • SULFATE
                                       * SELENIUM
                                       • ARSENIC
                                       • TDS
.55
.50
                                                   .45
                                                   .40
                                                   .35
                                                   .30 5?
                                                       cc
                                                       •0


                                                   .25 5
                                                   .20
                                                   .15
                                                   .10
                                                   .05
.55
.50
             .45
             .40 t
             .35
          g.30
          uf -25
             .20 t
             .15
             .10
             .05 t
                       TIME (HOURS)
                                                  FIGURE 7
                                 MODELED 1-YEAR/30-MINUTE STORM RUNOFF
                                   CHARACTERISTICS  FOR  GREENWICH ASH
                                 TIME (HOURS)

-------
120-'
                                           LEGEND
                                            4  SULFRTE
                                            *  SELENIUM
                                            •  ARSENIC
                                            •  TDS
                                  14
                             TIME (HOURS)
                           FIGURE  8
            MODELED 1-YEAR/24-HOUR  STORM RUNOFF
             CHARACTERISTICS FOR  GREENWICH ASH
                               272

-------
                     TABLE 13




RESULTS OF MODIFIED 5SWMM MODEL FOR A 5-ACRE ASH AREA
Storm Event
Ash Runoff Volume
(sal)
As
1-year/ 30-minute

1 -year /2-hour

l-year/6-hour

1-year/ 24-hour

10-year/ 24-hour

Benjamin
Greenwich
Benjamin
Greenwich
Ben j amin
Greenwich
Benjamin
Greenwich
Benj amin
Greenwich
11,848 0.
0.
24,235 0.
0.
36,188 0.
0.
32,418 0.
0.
47,176 0.
0.
02
01
04
03
05
04
03
02
07
05
Total Pollutant Load
Washed Off Ash Pile
(Ibs)
Se
0.01
0.01
0.02
0.02
0.03
0.03
0.02
0.02
0.04
0.04
S°4
9
11
18
22
27
33
15
19
34
41
.1
.0
.4
.3
.5
.3
.9
.2
.1
.3
TDS
4
3
8
7
12
11
7
6
15
14
.2
.9
.5
.9
.7
.8
.3
.8
.8
.6
Pollutant Concentration in
Hypothetical Collection Pond
(rng/1)
As
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
18
14
18
14
19
14
18
13
18
13
Se
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
10
10
11
10
11
10
10
10
10
09
SO, TDS
4
90.8 42.0
109.8 38.9
90.6 41.9
109.5 38.8
91.1 42.1
110.2 39.1
87.1 40.2
105.3 37.3
86.4 40.0
104.4 37.0
                  EPA Drinking Water Standard
0.05     0.01     250.      500.

-------
                        Investigation of Site Geohydrology
 The 170-acre site of the planned fly ash landfill is  located  about  one-
 half mile from the generating station (Figure  1).  It is  relatively
 flat-lying,  with the maximum relief being only about  55  feet.   Several
 intermittent streams cut across the site,  although the majority of  them
 appear to be diversion channels constructed  for the purpose of  drainage
 control.   Prior to its being purchased  by PP&L,  the land  was  used for
 the farming  of crops.

 Geohydrological conditions  at the site  were  investigated  by means of
 test borings,  test pits,  hand auger holes, monitoring wells,  and field
 examinations.   What emerged is a picture of  a  fairly  simple ground  water
 aquifer system.   This  system is depicted in  the generalized geologic
 section of Figure 9.   Basically,  the majority  of  ground water flow  is
 confined  to  a  rather narrow zone represented predominantly by a weathered
 and highly fractured shale.   Immediately above this zone  is a uniform
 silty clay of  extremely low permeability, which acts  as a cap on the
 ground water aquifer.   Below it is  a very  tight (few  open fractures)
 unweathered  shale with nearly horizontal bedding,  which acts as a bottom
 confining layer on the aquifer.

 The hydraulic  gradient over the site is about  1:120 and the rate of
 ground water flow is probably on the order of  only 0.05 feet per year
 (based on a  calculation using an assumed value for the permeability of
 the fractured  shale).   The  water  table  occurs  at  a depth of 5 to 10 feet
 and its configuration  generally conforms to  the  site  topography.  Unlike
 the drainage ditches,  which are probably perched  on top of the clayey
 soil,  the one  large intermittent  stream which  traverses the site appears
 to  be  connected  to the ground water  system,  since the  ground water
 contours  indicate a depression in that  area.   This  is worth knowing,
 because the  stream is  located along  the  down-gradient  border of the site
 and  could  therefore possibly  be  used  as  a hydraulic barrier against the
migration  of any  pollutants which might  enter  the  ground water system
 upstream.

Local wells in  the  area range  in depth  from about  30  feet for those that
were hand  dug  to  nearly 300 feet for  those that were drilled.   The water
is used predominantly  for human consumption and livestock watering.   The
quality of the water is generally acceptable for  these purposes, except
that it contains  unusually high concentrations of  sulfur and iron due to
the presence of iron sulfide minerals in the local bedrock.   Thus,  any
pollutant   introduced into the  ground water might have an impact which
should be   considered in the overall design concept  for the landfill.
                                      274.

-------
FT.


 0
 10
 15
20
25
30
35
U.QLJ
oz>
  uo
LUOZ
za:
OC3
                     .........
                     r .— •-—.— •-r.7^. -r.-.T- -.r
                    .p*f.'.1T.'.t».'.VRr. I IL . j I r.'ffT.'.rr/...



                    ''''''''

                      TO DEPTH
                         MOTTLED SILTY CLAYj  NO STRUCTURE
                                   SILTY CLAY SAPROLITEi SOME STRUCTURE
                                   WEATHERED SHflLEj ABUNDANT OPEN,
                                   STEEPLY DIPPING JOINTS* "RUSTING'
                                   "TIGHT", UNWEATHERED MARCELLUS
                                   SHALEj BEDDING NEARLY HORIZONTAL
                              FIGURE 9
                 GENERALIZED  GEOLOGIC  SECTION
                                  2/5

-------
                            THE LANDFILL DESIGN CONCEPT
                              AND PLAN OF OPERATIONS
 The laboratory simulations and modeling and the geohydrological investi-
 gation provided valuable input into determining how the fly ash landfill
 should be designed and operated.

 First, the leaching simulations showed that certain pollutants,  such as
 arsenic,  selenium, and possibly sulfate, would likely appear in the
 leachate  in concentrations above  the EPA's drinking water  standards  for
 protecting human health.   They also showed that these same pollutants
 could not be expected to be attenuated to any great extent by the  site
 soil.   From the geohydrological investigation it was found that  attenua-
 tion by dilution could not be relied on either because of  the slow rate
 of  ground water movement and the  confined nature and limited vertical
 extent of the ground water aquifer  system.

 Thus,  it  was decided to collect all of the leachate for possible treatment
 or  combination with other waste streams,  either on  site or back at the
 generating station.   What was especially appealing  about this scheme  was
 that no special liner would be required,  since the  natural clays at  the
 site could serve this purpose with  the need for only simple in-place
 reworking to remove any remnant structures (open fractures)  which might
 still be  present from weathering  of the parent rock material.  Physical
 tests performed on the station's  bottom ash also showed it to  be quite
 suitable  as  a drainage blanket material,  except that a filter  fabric  of
 some sort would have to be used on  top of the  blanket to prevent its
 becoming  clogged with the finer fly ash particles.

 The  results  from the runoff simulations showed that,  despite  the storm
 event  involved,  the collected runoff from the  operating portions of the
 landfill  would  again contain concentrations  of arsenic and selenium in
 excess  of the drinking water standards.   While it was  uncertain what
 discharge limitations  might be placed  on  the outfall pipe  from a collec-
 tion facility,  the  available receiving streams in the  area are so small
 that no in-stream dilution  could be  relied upon to  assure  compliance
with water quality  criteria.   After  all,  it  was  the violation  of these
 criteria  that necessitated  the switch  from a wet to  a  dry  ash  handling
 system  in the first  place.   To  reduce  the volume of  contaminated runoff
likely  to be  produced  by  the  landfill,  the size of  the  active portion
 could be  reduced.  This has  the added  benefit  of also  reducing the
potential fugitive dusting  problem,  as well  as  the  amount  of leachate.
A working cell  size  of  5  acres was finally selected  as  representing the
best compromise between these  concerns and operating efficiency.

The problem of what  to  do with  the leachate  and "dirty" runoff (as
compared  to the "clean" runoff  from  unworked or revegetated portions of
the landfill) is  still being  addressed.   One alternative, which has
received additional  study effort,  involves combining  the two waste


                                      276

-------
streams with enough clean runoff to lower the pollutant concentrations
in the final discharge to an acceptable level.  This scheme has a great
deal of appeal because it would eliminate the need to install a sophis-
ticated metals treatment system based exclusively on laboratory generated
data.  A drawback of the scheme is that it would require a fairly large
collection pond.  Calculations show, for instance, that it would take
about 50 acres of clean runoff to adequately lower the pollutant levels
in the leachate  (assuming full site development and 5% infiltration of
the precipitation falling on the landfill).  The problem with constructing
such a large basin is that the thinness of the site soil and the low
relief at the site may limit the capacity which can be achieved by
excavation or diking while still allowing gravity flow into the basin.

An alternative is to pump the leachate and dirty runoff back to the
generating station for combination in the waste detention pond, which
also has some pH control capability.  A disadvantage of this scheme is
that it would require a very reliable pumping system; and should that
system fail, the collected wastes would have to be discharged with
essentially no reduction in pollutant concentrations.  This may not be
acceptable under the EPA's developing Best Management Practices require-
ments.  Also, there is the concern that the chemistry of the leachate
and runoff may not be compatible with the other wastes in the detention
pond and may create a new problem at that location, even with adequate
pH control.

As a means of verifying the laboratory data, another step being considered
by the company is to prepare and monitor a test plot at the landfill
site.  Based on this data it should be possible to make a more definite
decision about the need for treatment and the advisability of the various
flow combination schemes being considered.  The problem, of course, is
which ash samples and which arrangement of the different ash types will
produce the most representative results—one of the same limitations of
the laboratory effort.
                                    277

-------
                                 BIBLIOGRAPHY
 1.   Furr, A.K., et al., "National Survey of Elements and Radioactivity
     in Fly Ashes," Env. Sci. & Tech., Vol. 11, No. 13, 1194-1201 (1977).

 2.   Coles, D.G., et al., "Chemical Studies of Stack Fly Ash from a
     Coal-Fired Power Plant," Env. Sci. & Tech., Vol. 13, No. 4, 455-459
     (1979).

 3.   Smith, R.D., et al., "Concentration Dependence upon Particle Size
     of Volatilized Elements in Fly Ash," Env. Sci. & Tech., Vol. 13,
     No. 5, 553-558 (1979).

 4.   Ondov, J.M., et al., "Emissions and Particle Size Distribution of
     Minor and Trace Elements at Two Western Coal-Fired Power Plants
     Equipped with Cold-Side Electrostatic Precipitators." Env. Sci. &
     Tech., Vol. 13, No. 8, 946-953 (1979).

 5.   Ondov. J.M., et al., "Elemental Emissions from a Coal-Fired Power
     Plant, A Comparison of a Venturi Wet Scrubber System with a Cold-
     Side Electrostatic Precipitator, Env. Sci. & Tech., Vol. 13, No. 5
     598-607 (1979).

 6.   Theis, T.L., and Wirth, J.L., "Sorptive Behaviour of Trace Metals
     on Fly Ash in Aqueous Systems," Env. Sci. & Tech., Vol. 11, No. 12,
     1096-1100 (1977).

 7.   Houle, T.L., and Long, D.E., "Accelerated Testing of Waste Leacha-
     bility and Contaminant Movement in Soils," in Land Disposal of
     Hazardous Wastes, Proc. of Fourth Annual Symposium, U.S. EPA,
     Cincinnati, Ohio, 152-168 (1978).

8.   Roberts, B.K.,  "Simulated Field Leaching Test for Evaluation of
     Surface Runoff from Land Disposal of Waste Materials," IU Conversion
     Systems, Inc.,  Report to ASTM D-19 Subcommittee,  Nov. 3, 1977.

9.   	,  "Technical Paper No. 40:   Rainfall  Frequency Atlas of
     the United States for Durations from 30 Minutes to 24 Hours and
     Return Periods  from 1 to 100 Years",  U.S. Dept. of Commerce, Weather
     Bur.,  Wash., D.C.,  61 p.  (1961).
                                      273

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                    MEASUREMENT OF FUGITIVE EMISSIONS

                     FROM INCO'S  COPPER CLIFF  SMELTER

                     PART III:  REVERBERATORY FURNACES
    A.D. Church


 W.J. Middleton


       P. Gatha



ABSTRACT
Superintendent, Smelter Process Technology,
Copper Cliff, Ontario.

Section Leader, Smelter Process Technology,
Copper Cliff, Ontario.

Project Leader, Smelter Process Technology,
Copper Cliff, Ontario.
     The Copper Cliff Smelter of Inco Metals Company, a major primary nickel
and copper producer, is located in Ontario, Canada.  The essential  processing
equipment consists of Multi-Hearth Roasters (^30), Reverberatory Furnaces (6),
Oxygen Flash Furnace and Peirce-Smith Converters (18).  A comprehensive
program to measure fugitive emissions of sulphur dioxide, sulphuric acid and
particulates from the Smelter is being undertaken.  This paper describes the
reverberatory furnace section of this program.

     Total fugitive emissions of sulphur dioxide, particulates and  sulphuric
acid from the reverb furnaces were measured as 15.2, 0.19, and 0.12 kg/Mg of
bessemer matte equivalent respectively.  Nearly 70% of the emissions occur
during matte tapping.  Slag skimming and furnace "puffing" contribute 20% and
3% respectively.  Total fugitive sulphur dioxide emissions were found to be
equal to those being emitted by all the converters (previously measured).
However, most of the fugitive gas (^90%) was captured at source by  hood
systems before release to atmosphere at roof level.
                                     279

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 INTRODUCTION

     A major program of measurement of fugitive emissions originating from
 the Copper Cliff Smelter of  Inco Metals Company has been undertaken.  The
 objectives of this program are:  (a)  identification of sources of fugitive
 emissions, (b)  determination of sulphur dioxide, particulates and where
 possible, sulphuric acid concentrations in these emissions, (c)  correlation
 of the fugitive emissions to the unit operations and the throughput of the
 Smelter and (d)  to curtail  the fugitive emissions.

     Fugitive emissions originating from copper and nickel converters have
 been previously determined and reported}'2  This paper describes the findings
 pertinent to nickel reverberatory (reverb) furnace activities in the Smelter.

     There are at present six nickel reverb furnaces in the Smelter of which
 usually three or four are operating at any one time.  Four activities
 associated with reverb furnace operation produce significant quantities of
 fugitive emissions.  These are matte tapping, slag skimming, furnace "puffing"
 and return of converter slag.  Emissions from the last source had been
 previously estimated.2  A general layout of a reverb furnace (No. 3) and
 associated hoods and vents is shown in Figure 1.  Emissions arising during
 matte tapping are collected by the hoods above the matte tunnel and the matte
 launder, gathered in a fan-forced vent and exhausted to atmosphere via a
 "black ship" ventilator at roof elevation (^50m).   Similarly, slag skimming
 emissions are collected in another vent and released into a roof ventilator
 above the furnace and thence to the atmosphere.  Emissions due to furnace
 "puffing" rise by convection and exit the building via the same roof
 ventilator.

     Consequently, the measurement program was divided into two phases.
 Phase I consisted of the determination of sulphur dioxide, particulates and
 sulphuric acid in gases in the vents at the matte tunnel, and matte and slag
 launders, while Phase II involved measurement of the same in the roof
 ventilator.  In the latter case measured emissions represented a combination
of slag skimming and furnace "puffing" activities.  Thus emissions due to
slag skimming were measured twice which was considered useful  to verify the
 results.

     The measurement techniques were essentially the same as those employed
in previous work2, with the exception of a method  for determining sulphuric
acid.   Previous attempts to measure sulphuric acid using an isopropanol
capture system (EPA method 5) were unsuccessful.  In the present study,
sulphuric acid serosols were collected together with particulate matter on
the same filter and were subsequently determined by chemical analysis.
                                     280

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EXPERIMENTAL

Phase I

     This phase, as mentioned earlier, involved measurement of emissions  in
the vents from the matte tunnel, the matte launder and the slag launder.

     Sampling points were installed at suitable locations  in the three  vents
and gas velocities were determined with an S-type pitot.   Volume flows  were
calculated and from velocity profiles, points representing average velocity
were determined.

     A sampling train as shown in Figure 2 was assembled.   The gas sample was
drawn continuously with a pump through a Balston filter* for particulate  and
sulphuric acid collection and was then directed to hydrogen peroxide
solutions in impingers to caputre sulphur dioxide.  Typically, sampling was
done continuously for an eight hour period at the end of which the filter was
removed, dried and weighed.  Subsequent chemical analysis  determined the
sulphuric acid content on the filter.  The hydrogen peroxide solution was
titrated with sodium hydroxide (IN) and the quantity of sulphur dioxide was
calculated.  Using values of previously determined volume flows in the  vents,
total sulphur dioxide, particulate and sulphuric acid emissions for the eight
hour period were determined.  These were then expressed in terms of quantity
per ladle of matte tapped or slag skimmed.  In all, emissions were monitored
for about 56 hours at the matte tunnel, 16 hours at the matte launder and 48
hours at the slag launder, covering the tapping of some 86 ladles (VI700  Mg)
of matte and the skimming of 83 ladles (-v/2000 Mg) of slag.

Phase II

     In this phase, emissions in the roof ventilator above the furnace  were
measured.

     The roof ventilator consisted ofa5.9mx7.6m section of transite
stack of approximately 26 m in height and starting about 29 m above the
furnace level.  The ventilator was of the gravity flow type with non-uniform,
low velocity gas flow profiles (see Figure 1).

     The methods used in this phase were the same as those described in the
previous study at nickel converters.2  The sampling and analysis systems  are
shown in Figure 3 and 4 respectively.  The sampling system was installed in
the ventilator and was connected to the analysis system.  The anemometer vane
and thermocouple were fixed at positions representing average gas velocity and
temperature and were connected to recorders.

* Manufactured by Balston Filter Products, Lexington, Massachusetts, U.S.A.
                                     281

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      Actual monitoring covered 19 shifts (VI50 hours)  divided into two
 sessions.  Two technicians operated the analysis system on M-floor and
 one technician was located at the skimmer's platform.   The latter recorded
 beginning and ending times for each ladle skimmed and  transmitted this
 information via radio to the technician at the analysis station.   Data was
 thus recorded on a per "event" basis where an "event"  was  defined as  either
 a "skimming event" (representing emissions due to skimming and  "puffing")  or
 a "non-skimming event" (representing "puffing" emissions only).

      Data recorded for each "event" included  (a)   activity,  (b)   duration  of
 the activity (5-15 minutes), (c)  sample gas  volume  (50-300  litres),  (d)
 titrant (0.1N NaOH) volume, (0.1 to 10 ml), (e)   gas velocity (4-5 m/s), and
 (f)  gas temperature (10-20 C).

      The staplex filter was changed every shift  (eight hour  period),  dried
 overnight in a desiccator and weighed to obtain  the combined weight of
 particulates and sulphuric acid  (50-500 rug).   The quantity of the acid was
 subsequently determined by chemical  analysis.  For each filter this data was
 recorded together with corresponding sample gas  volume and the ventilator  gas
 velocity and temperature.

      Furnace draft was recorded  at  15 minute  intervals with  a viewpoint of
 establishing a relationship between  the draft  and "puffing"  emissions.

 DATA ANALYSIS

 Fugitive Emissions -  Return Of Converter Slag

      These  emissions  occur at the converter aisle end  of the furnace and have
 been calculated  in a  manner similar  to  that used  in the previous  study of
 nickel  converters.2   It was  assumed  that  the quantity  of sulphur  dioxide
 emitted  during this process  was  the  same  as that  when  skimming a  ladle of  the
 furnace  slag  (12.1  kg/ladle  from this study).

 Phase I
     Total fugitive emissions per ladle for matte tapping activity were
calculated as the sum of the two separate components measured in the matte
tunnel and launder respectively, both of which later combined and exhausted
to the atmosphere.  Total rate and average concentration of emissions were
similarly derived.  Fugitive sulphur dioxide emissions per ladle for slag
skimming activitiy were also calculated.  The latter were used for comparison
with the measurements made in the roof ventilator.
                                     282

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Phase II

     A computer program was developed to calculate  for  each  shift  both  total
sulphur dioxide emission and rate and concentration of  the emission  on  a  per
"event" basis.  A preliminary examination of results thus obtained indicated
that emissions during a non-skimming "event" immediately following (1-3
minutes) a skimming "event" were invariably higher  than during  other non-
skimming "events".  This is shown in Figure 5.   A closer examination of a
typical "skimming event" as shown in Figure 6 revealed  that  a portion of  the
emissions actually attributable to the skimming activity was being counted  as
non-skimming or "puffing" emission.   This carry over of emissions  occured
because a "skimming event" was considered terminated as soon as that activity
stopped at the skimmer's platform, while the resultant  change in emissions
recorded at the analysis station (some 50 metres above  the furnace)  was not
instantaneous.

     Therefore, while total sulphur dioxide emissions per  shift calculated
by the computer were correct, distribution between  skimming  and "puffing"
activities was erroneous.  The following approach was used to calculate
sulphur dioxide emissions from skimming and "puffing" activities:

     1.  Total S02 (kg) per shift obtained from computer printout  -  Et

     2.  Average rate of emission (kg/min) during non-skimming
         "events" calculated from computer output,  excluding
         "events" immediately following a skimming  "event"         -  R

     3.  Emission due to "puffing" - E  (kg) = R  x time (minutes)

     4.  Emission due to skimming - E  (kg) = E. -  E
                                     5 ,         Up

     5.  Emission (kg) ladle                = ES/NO. of Ladles

     The particulate and sulphuric acid emissions were also  calculated  in
terms of kilograms per ladle from the data obtained for each filter.  Owing
to very low concentrations of the particulates, the filter was  changed
approximately every eight hours.  Therefore, the particulate and sulphuric
acid emissions were not correlated with skimming and "puffing"  activities
separately, rather the results represented a combination of the two
activities.

     Finally, fugitive emissions were expressed in terms of unit production
of bessemer matte* using relevant production data,

* Bessemer matte is the final output of the nickel  circuit in the Smelter
  and contains Ni (50%), Cu  (25%), and S  (22%).
                                      283

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 FUGITIVE SULPHUR DIOXIDE EMISSIONS

      Total fugitive sulphur dioxide emissions from reverb furnaces  were
 determined as 15.5 kg/Mg bessemer matte.  Of these about 70% originated
 from matte tapping activity while slag skimming contributed 20% of  the
 total.  The remainder was attributed to furnace "puffing" and the process
 of returning of converter slag to the furnace.   Results  are shown in  Table  1.

      On a per ladle basis the sulphur dioxide emissions  were 64 - 12  kg
 during tapping and 12.1  * 2.9 kg during skimming.   The  latter figure  compared
 well  with the value of 11.2 ± 4.2 kg obtained during  Phase I.

      The average rates of sulphur dioxide  emissions during tapping, skimming
 and "puffing" were found to be 5.1, 1.4, and .06 kg/min.,  respectively.  The
 average maximum rate of emission was therefore  about  6.5 kg/min.  The rate  of
 "puffing" emissions showed no clear relationship with the furnace draft.
 However, the observed variation in the draft during the  entire  test was"very
 small  which presumably effected a change in  sulphur dioxide emissions too
 small  to be detected by  the present technique.

      The average sulphur dioxide concentration  in  the matte tapping emissions
 was 7400 mg/m3 (2470 ppm)  while that in  the  skimming  emissions  was 180 mg/m3
 (63 ppm).   These were the concentrations in  the  emissions  on entry to the
 atmosphere.   The slag skimming emissions were diluted some twenty fold  in the
 roof  ventilator prior to release to the  atmosphere, therefore,  the concentra-
 tion  of sulphur dioxide  was  much lower.  The average  sulphur dioxide  concen-
 tration in  the "puffing"  emissions  was found to  be  8  mg/m3  (2.8 ppm).

 FUGITIVE PARTICIPATE  EMISSIONS

     Total  patticulate emissions from  reverb furnaces were  0.19 kg/Mg
 bessemer matte of which  like  sulphur dioxide, nearly  70% were attributable
 to  matte tapping  while the  rest  was contributed  by slag skimming and
 "puffing" activities.  Results are  summarized in Table 2.

     The average  rate and concentration  of particulate emission from
matte  tapping  were  .06 kg/min. and 81 mg/m3 respectively.  The mean combined
rate of  particulate emissions due to slag skimming and furnace "puffing" was
 .009 kg/min.   The corresponding  concentration was about 1.2 mg/m3.

     The main  constituents of the particulates from matte tapping were
sulphur  (13%)  and iron (5%) with copper and nickel being found in lower
amounts.  Particulates collected at the roof ventilator consisted mainly
of iron  (30%), copper (5%), and nickel (7%).
                                    234

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FUGITIVE SULPHURIC ACID EMISSIONS

     Total sulphuric acid emissions from reverb furnaces were measured as
0.12 kg/Mg bessemer matte.  Distribution of the emissions between matte
tapping, slag skimming and "puffing" was much the same as for sulphur
dioxide and particulates.  Results are shown in Table 3.

     Average rates and concentrations of the emissions during tapping were
.04 kg/min. and 52 mg/m3 respectively.  Those attributable to slag skimming
and "puffing" were .006 kg/min. and about 0.8 mg/m3 respectively.

     In general, sulphuric acid emissions were proportional  to sulphur
dioxide emitted.  A plot indicating this relationship is shown in Figure 7.

     Average sulphuric acid/sulphur dioxide ratio found in this study was
about .010 which was similar to the value obtained during recent tests
conducted on gases in the main chimney of the Smelter.  This ratio was also
fairly constant, the relative standard deviation being ± 25%, indicating
that capture of sulphuric acid on the filter was probably quantitive.  This
was considered indirect support for the technique used for the measurement
of sulphuric acid.

DISCUSSION

Precision and Accuracy

     In previous studies of copper and nickel converters no attempt was made
to determine the precision of the measurements.  This was mainly due to the
complexity of the converter operations, particularly in the case of nickel
converters where interaction of emissions from two or more converters
occured prior to reaching the measurement system.  Consequently only a sub-
jective estimate of precision was made, which was - 10% for the copper
converters and ± 90% for the nickel converters. :'2

     In the present study on the nickel reverb furnace, the system was found
to be more exact, with little or no interaction between emissions from
different units and also with a good separation of emissions from various
activities of the furnace.  Thus precision (S.D./mean x 100) could be
determined on per ladle basis.

     For sulphur dioxide emissions this was found to be - 20% for matte
tapping and ± 24% for slag skimming.  It should be emphasized that these
values represented the overall fluctuations in the emissions, the precision
of the measurement technique itself was considered to be much better.
                                     235

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      In  addition,  slag  skimming emissions were measured at two locations
 employing  different  techniques.  The results are compared in Table 5.  The
 sulphur  dioxide emissions were measured as 11.2 kg/ladle in the vent from the
 slag  launder  (Phase  I)  which showed a good agreement with the value of 12.1
 kg/ladle obtained  in the roof ventilator (Phase II).  Similarly the rate of
 sulphur  dioxide emission of 1.5 kg/min. in the vent compared well with the
 rate  of  1.4 kg/min. measured in the ventilator.  Finally, the concentration
 of sulphur dioxide in the emissions was found to be 180 mg/m3 in the
 ventilator.  The same measured in the vent was 3080 mg/m3 which was sub-
 sequently diluted  17 times in the roof ventilator to give a value of
 181 mg/m3.  These comparisons were indicative of the high accuracy of the
 measurements.

 GENERAL

     Total sulphur dioxide fugitive emissions from reverb furnaces were
quite similar to the total  converter fugitive emissions.  This is shown
 in Table 5.  The particulate emissions from reverb furnaces were about
 the same as those from  nickel  converters while copper converters emitted
much larger quantities  of particulates.   This was chiefly due to periodic
addition of very fine flotation concentrate to the copper converters.  An
important difference between fugitive emissions from reverb furnaces and
converters was that essentially all  of the emissions from furnaces (^902)
were captured at source by hoods before being released to the atmosphere.
The converter fugitive  emissions were uncaptured and tended to wander before
 leaving  the building via roof ventilators.   This difference was reflected in
the quality of work room air in the two areas.   The average eight hour
reverb furnaces were found to be 0.9 ppm and 0.2 mg/m3 respectively,
compared to the corresponding average values of 2.5 ppm and 5.5 mg/m3 found
at the converters.

CONCLUSIONS

     1.  Measurement of fugitive emissions  from nickel  reverberatory
         furnaces has been  successfully completed.   The precision of
         the measurements was  estimated as  ± 20%.

     2.  Matte tapping activity was  the major source of fugitive
         emissions, contributing about  70%  of the  total  with  slag
         skimming (20/0  and other activities  contributing the remainder.

     3.  Essentially all the fugitive emissions  (^90%)  were captured at
         source before being emitted to  the atmosphere.
                                   286

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     4.   Daily fugitive sulphur dioxide emissions  from the  reverb
         furnaces (15.5 Mg)  were similar to  the  total  daily converter
         fugitive emissions  (13.8 Mg).

     5.   Judged by the criterion of the constancy  of sulphuric  acid/
         sulphur dioxide ratio, the present  technique of  capturing
         the acid by filtration seemed to be satisfactory.
REFERENCES
         "Measurement of Fugitive Particulate and Sulphur Dioxide
         Emissions at Inco's Copper Cliff Smelter",  A.D.  Church,
         C.  Landolt and F.  Boniakowski;  presented at the  108th
         AIME Annual meeting in New Orleans,  Louisiana, February
         1979.

         "Measurement of Sulphur Dioxide and  Particulate  Fugitive
         Emissions From the Nickel and Copper Converter Operations
         at Inco's Copper Cliff Smelter", A.D. Church,  C. Landolt
         and F.  Boniakowski; presented at the 18th Annual Conference
         of Metallurgists sponsored by Canadian Institute of Metallurgy
         in Sudbury, Ontario, August 1979.
                                    237

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Rgure   1
Vent Arrangements at N8 3 Reverb Furnace
    i Himri SampHng Point
    itaundv •
 Psia« Laanatr
                                                             JS/SPT/SO
                             288

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                        Figure  2
                        Sampling Train Used in Phase I
00
IO
                                                    1st Impinge rrf BBi  2nd Impinger

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                                                Figure 3
                         S02  and particulate monitoring system. (Phase ID
O


• — n —
1 — U —
Orifice
plate for


Dn<
Hurricane $;
_pump||t



;t
er










c

1 <
i

Ventilator.
3 Sets -Sample probes
for SOa and particulate
_ * Temperature recorder
	 ».f^ne uolnritu rorrvrrfor

	 »< "1 Ci«fl4^K USllwA

-Rj— IT
O Draft indicator
                        measurement

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K!
VO
                       Figure 4

                       Analysis System (Phase n)
                                  To Orifice
                  Event time  = 1-15 minutes

                  Sampling rate ~ 14 litres/min.
                          Pump



                        Dust filter

                               From Vent
       pH
       Electrode
       H202
        Solut
Istlmplnger    2ndlmpinger   Meter

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                Figure 5
                S02 Emissions during different events
                 l.2r
.
•
           HH Skimming event




           I	I Non Skimming event
                            20
100
120
140
160
180
200
                                                    TIME  (Minutes)

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Figure 6
S02 Emissions during Typical Skimming Event.
                        9        II
                           Time (Minutes)
  Ts = Recorded duration of a SKIMMING EVENT
  Tns=   "      "     " NON SKIMMING  EVENT
                              293

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                  Figure  7

                  Sulphur dioxide vs. Sulphuric acid.
NJ
IO
-P-
                   C 3


                   O

                   N
                   I
                                                                                                    •Mean
                                       IOO
2OO
300
4OO
                                                                S02(kg)

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                              TABLE 1
            Fugitive SO? Emissions From Reverb Furnaces
Activity
Matte Tapping
Slag Skimming
Puffing
Return Of
Converter Slag
Total
S0£
(kg/Mg B.M.)***
10.80
3.07
0.41
1.20
15.5
Emission Rate
( kg/mi n)
5.08
1.41
0.06
N/A*
6.55**
Concentration
(mg/m3)
7,390
180
8
N/A*
-
*   - Not Available
**  - Maximum
*** - Bessemer Matte
                                295

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                              TABLE 2
        Fugitive Particulate Emissions From Reverb Furnaces
Activity
Matte Tapping
Slag Skimming +
Puffing
Total
Participates
(kg/Mg B.M.)*
.119
.068
.187
Emission Rate
( kg/mi n)
.057
.009
.066**
Concentration
(mg/m3)
81
1.2
-
*  - Bessemer Matte
** - Maximum
                                296

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                              TABLE 3
      Fugitive Sulphuric Acid Emissions From Reverb Furnaces
Acti vi ty
Matte Tapping
Slag Skimming +
Puffing
Total
HzS04
(kg/Mg B.M.)*
0.077
0.043
0.120
Emission Rate
(kg/min)
0.037
0.006
0.043**
Concentration
(mg/m3)
52
0.8
-
*  - Bessemer Matte
** - Maximum
                                297

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                             TABLE 4
 Comparison of Slag Skimming Emissions Measured at Two Locations
Location
Vent From Slag
Launder (Phase I)
Roof Ventilator
(Phase II)
S02/Ladle
11.2 - 4.2

12.1 - 2.8
kg/mi n
1.5 - 0.4

1.4 - 0.3
mg/m3
181* 1 55

180 - 51
* Corrected for dilution in the roof ventilator.
                              293

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                               TABLE 5
Comparison of Fugitive Emissions From Converter and Reverb Furnaces
Source
Copper Converters
Nickel Converters
Total Converters
Nickel Reverb Furnaces
S02 (Mg/Day)
10.6
3.2
13.8
15.5
Particulates
(Mg/Day)
1.1
0.2
1.3
0.2
Sulphuric Acid
(Mg/Day)
N/A *
N/A *
N/A
0.1
    * Not Available
                                   299

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             CONTROL OF FUGITIVE EMISSIONS FROM COAL STORAGE PILES
                                 A. E. Veel
                          Research and Development
                                 C. H. Carr
                           Sinter Plant and Docks
                    The Steel Company of Canada, Limited
                         Hamilton, Ontario, Canada


                                   ABSTRACT

The Steel Company of Canada is a fully integrated steel producer with its
primary steelmaking facilities located in Hamilton, Ontario.  The basic end of
this operation consists of four coke batteries, four blast furnaces, one OH
shop and one EOF shop.

During the period December to March when the Great Lakes and the St. Lawrence
Seaway are ice bound, shipping of raw materials is curtailed and both iron ore
pellets and coal must be stockpiled to allow for continuous operations.  At
any one time approximately 83 acres of land is covered by up to 7 distinct
coals or coal blends.  Because the percentage of fines can be as high as 15
percent, coal dust particle movement by the wind can be severe.

MHTR Engineering was retained to examine the situation and to recommend
measures to alleviate the existing conditions.  This study was based on
constructing models of the site and testing them in a wind simulator to
determine the problem areas and to test the remedial solutions.

The study indicated that orientation and shaping of the coal piles were key
factors in controlling the turbulence which resulted in particle movement.

Suggested solutions which have been implemented have significantly reduced
the problems associated with storage of coal in open sites.
                                     300

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            CONTROL OF FUGITIVE EMISSIONS FROM COAL STORAGE PILES
Over the past few years environmental legislation has focused on control of
point sources of industrial emissions.  While this control has led to improve-
ments in the levels of tsp in the ambient environment there has been a greater
recognition that fugitive emissions are also significant contributors to urban
dustfall levels.  In an integrated steel plant a large source of potential
fugitive emissions is raw materials storage piles.

One of the world's major integrated steel companies, Stelco is ranked No 1 in
Canada, and No 9 in North America.  Steel production at its primary facilities
in Hamilton, Ontario, at the western end of Lake Ontario, some 60 miles north-
west of Buffalo, New York, is approximately 6 million ingot tons per year.
When a greenfield expansion program, now in progress, is completed, it is
estimated that the Company's production will eventually double to 12 million
ingot tons per year.  This greenfield site is located on the shore of Lake
Erie, opposite Erie, Pennsylvania.

Three basic materials — iron ore, coal and limestone — are needed to make
steel.  Coal and iron ore are most economically shipped by water transport to
Stelco's docks at Hamilton.  These facilities handle over 370 ships each year.
Since it takes 1 ton of iron ore, ^ ton of coal and miscellaneous flux
materials to produce 1 ton of steel, a company the size of Stelco must handle
approximately 10 million tons of bulk raw materials each year at its Hamilton
plant.  At any one time the coal storage piles cover approximately 83 acres of
land (roughly 1/10 of the total area covered by these operations) and because
up to 7 different coals or coal blends are utilized, the coal storage area is
comprised of several separate piles rather than one large continuous pile.

As mentioned earlier the majority of raw materials are shipped through the
Great Lakes waterway system.  Coal from Kentucky and West Virginia must cross
Lake Erie and move through the Welland Canal system, bypassing Niagara Falls,
in order to reach the facilities at Hamilton.  However, due to the severe
Canadian climate this method of transport is not available from December to
March each year.  As a consequence the storage piles are considerably larger
than those kept by most United States steel companies.  Allowing for the four
months that the waterway is impassable and a one-month safety factor to ensure
a continuation of operations should strikes occur within any of the unions
involved in shipping, shore handling and mining, there is a requirement to
store approximately five months' supply of raw materials at the end of every
snipping season.

The coal arrives at Hamilton in self-unloading vessels.  A conveyor deposits
tne coal in a conical pile on the dock.  Water is continually sprayed on the
coal to limit dust blow-off during the unloading process.  A bulldozer is
used to level this conical pile permitting large mobile scrapers to transfer
the coal to the storage piles, which may be up to 1100 ft in length, and
deposit the new coal in thin layers.  This layering process is used to
partially blend the old and new coals.  During the passage of the  scraper a
great deal of coal dust is released into the air.  A similar process in

                                      301

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 reverse is used during the ex-stocking process  when the coal  is  removed  from
 the storage piles and taken to the Coke Ovens.

 In periods of elevated wind speed fugitive  emissions may be generated at  the
 f o1low ing t imes:

      • when the coal  drops from the conveyor  to the conical pile,

      • general wind erosion from the conical  pile,

      • during the period  the scraper is traveling over  the storage
        piles or the arterial roads,  and

      • general wind erosion from the long-term  storage  piles
        themselves.

 Several of these  problem  areas  were  recognized  many years ago and solutions
 were  implemented  to control the problems.   During unloading:

      • water sprays were  directed into  the  unloading coal, stream and
        conical piles,

      • the free-fall  height of  the  coal was minimized by lowering the
        conveyor as much as possible,  and

      • a protective enclosure was attached  to the conveyor to minimize
        wind access to the  falling stream of coal.

 While these precautions were satisfactory under normal  atmospheric conditions
 with  extremely high winds  they  did not  suffice and  unloading operations had
 to  be terminated.

 In  order to minimize  dusting while the  scrapers move along the roads and
 storage  piles  tanker  trucks  were  used to spray water in the summer.  In the
 winter these same trucks were used to spray waste oil onto the roadways.   The
 storage  piles  were coated with  a  binding agent near the end of the shipping
 season.   This  was only a limited  success.  Some of  the problems associated
 with  wind  loss from storage  piles were  reduced by the above measures.  A key
 step,  however, was the reduction  of  the number of storage piles to six.   This
 allowed  for  both an orderly  layout of the piles and contouring of the piles.
 A final  step  in these early  efforts was the adoption of a procedure whereby
 coal  was  removed only from the end of the storage pile during winter months.
This  eliminated disturbance of the top surface of the pile during the winter
when water  spraying could not be utilized.

While  these  steps were successful to some degree, incidents of wind erosion
of  the storage piles resulting in blowing coal dust continued to occur
especially during the extreme conditions experienced in winter.   At this
 time  a consultant (Morrison, Hershfield, Theakston and Rowan), who had
considerable experience in the study of wind-blown materials as well as wind
 tunnel and water flume testing was retained.  The problem as presented to the
consultant was to determine the areas of coal loss from the storage piles and
 to  recommend methods for control.  A second phase involved a study of surface
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binders to determine the best product to be used to coat the storage piles to
carry through the winter period.

On the first phase of the study the technique used consisted of a model
analysis by employing an open channel water flume especially designed for the
study of particle movement and control.  This flume is 40 ft long, 4 ft wide
and 18in deep.  By varying the depth of water a variety of wind velocity
conditions can be simulated.  Particles of coal were simulated by silica sand
and wind movement was observed by injecting a dye into the flowing water to
indicate turbulence and direction.

A model was constructed of the complete site including the terrain, buildings,
conveyors, stacks, ore piles, coal piles, the unloading docks and surrounding
water area as well as separate models of the coal piles.  The model of the
site was used to determine the general flow pattern of the wind and the
effect of the various components comprising the site.  The models of the coal
piles were used in assessing, in detail, the effect of orientation and shape
of the piles.


Water Flume Test Results

Since wind direction is an important factor in the movement and entrainment
of coal particles, the water flume allows for the rotation of the model to
simulate changes in wind direction.  In the Hamilton region south-west and
westerly winds are predominant.  In all cases coal piles transverse to the
wind direction and even at a slight angle to the wind created turbulence on
the lee side of the pile.  With consecutive piles a channel was created to
carry the particles at a higher velocity, due to the venturi action, to the
leeward side of the site.  Coal piles located in line with the wind
eliminated the turbulence.  Based on this result a decision was made to
reorient the axis of the storage piles 'so that they would be in line with
the prevailing wind.  This required changing the entire field arrangement and
was carried out over one shipping season.

Shaping of the coal piles is an important factor in reducing turbulence due
to sharp edges and scour action.  Reduction of sideslopes will reduce the
scouring at the top of the slopes and the optimum slope is 1:7.  However,
steeper slopes will have progressively detrimental effects from 1:7 sideslopes
to 1:1 sideslopes.

While we were able to achieve the ideal slope at the leading edge of the pile
which faces the prevailing wind using that flatter slope for all sides would
have required a coal storage area many times the size available.  We utilized
a rounded crown which was suggested as an alternative shaping program where a
1:7 optimum slope is not feasible.

yhen more than one coal pile with 1:1 sideslopes (angle of repose)  is used,
turbulence is pronounced on the leeward side and in the channels formed by
adjacent piling.  The 1:7 sideslopes used for optimizing wind flow  patterns
eliminates the turbulence and eddy action.
An alternative recommendation to the 1:7 sideslope consists of rounded
sideslopes or the employment of a porous fence along the windward portion and


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 top of the pile.   These alternatives  are  proposed  only where space
 limitations require a  1:1  sideslope.

 The leeward end of the piles,  where coal  is  ex-stocked in  the winter time,
 is an area of  particular concern.  The flume studies  indicated that the
 installation of a  12-ft high porous fence on top of the pile, approximately
 150 ft from the leeward edge,  would be effective in reducing turbulence.  As
 an alternative, three  4-ft high  snow  fences  placed 60 ft apart parallel to
 each other in  line,  and parallel to the leeward face, were shown to be
 equivalent to  one  12-ft high fence.   In fact, both of these methods were
 tried and  both proved  to be effective and the combination  of both is used
 in the field.

 The final  recommendation of the  study was to install a snow fence near the
 leeward edge of the  entire field to catch dust which may be entrained along
 the ground surface.  This  was  done and has proved  to be effective in
 controlling dust not caught in other  ways.

 All these  recommendations  have been acted on and the practices are in
 continuous use in  the  coal storage fields.   The coal piles were reoriented
 and reshaped as recommended by the consultants.
Wind Tunnel Test Results

The use of binding agents applied to coal piles is a current practice in
reducing  the movement of coal particles from storage piles.  In the second
phase of  the study, samples of six types of coal used by Stelco were compacted
in small  boxes to simulate a coal pile with a leading edge to the wind.  They
were coated with various combinations of six different binders and placed in
the wind  tunnel.  These tests were supplemented by small sample piles in the
field at  Stelco to test the weatherability of the various binding agents.

As a general rule the thickness of the crust formed was found to be a measure
of the effectiveness of the binding agent in reducing particulate movement.

The study was narrowed to two binding agents plus waste oil which is
generated internally at the plant.  All three were tried in test applications
on the actual piles for a complete winter season.  We have decided to use an
asphaltic product supplied by Flintcote as the main binding agent to be
applied to the piles at the end of each shipping season and to carry us
through to the spring.  Waste oil is used for the active area at the end of
the pile  and for road dust control during the winter time.

The binding agents are to be applied in November and again at the end of the
shipping  season to ensure that snowfall does not prevent us from getting the
agent directly on the surface before the main onslaught of winter.  During
the summer season, water is the main dust control agent on the piles and on
the roads.

An important feature of our control program has been the issuance of a
detailed  list of operating instructions for the coal field.  This involves
regular attention to a wind recording device as well as regular contact with
the local Weather Office for wind prediction on each shift.  Action to be
taken on prediction or recording of increased wind speeds is clearly recorded

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By these actions we have recognized that continuous attention to a remedial
program designed to combat fugitive emissions from coal storage fields is
required.  This prolonged study has shown that a combination of both physical
and chemical methods based on a scientific approach can result in significant
reductions in dust emissions from bulk storage sites.
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                     USE OF ROOF MOUNTED TYPE ESP'S IN IRON

                         AND STEEL INDUSTRIES IN JAPAN
                                 Senichi MASUDA

                      Department of Electrical Engineering
                  Faculty of Engineering, University of Tokyo

                     7-3-1, Kongo,  Bunkyo-ku,  Tokyo,  JAPAN

                                 SUMMARY

     The  first ROOF MOUNTED TYPE ESP  (REP)  in Japan  was  installed  in  March
 1972 at a  steel  converter shop (80  tons x  3 units)  in  KOBE  WORKS of  KOBE
 STEEL CORPORATION, LTD.  by the hand of  SUMITOMO  HEAVY INDUSTRIES,  LTD.(SHI)
 after a  cooperative  developmental  effort  made  by  both  companies.     This
 first REP  showed  a very  successful  result,   lowering  the  dust loading  from
 0.246 (g/Nm ) at  its  inlet down to 0.032  (g/Nm )  at its  outlet  (collection
 efficieny:  87 %).    Thus, it proved to be one of  the most effective  means  of
 fugitive emission control  in  the  iron and steel  industries.   The  first  aim
 of this  development was to solve the problem of a limited installation site.
 However, it  has  become  clear  after the  start  of  its operation that  this
 solution using a  thermal  lift  of hot  dirty gas  itself  has  several  other
 large advantages  compared to an  alternative solution using  forced  suction
 and bag-house.

    The first  of  these  additional advantages is its inherent extremely  energy
 saving character  resulted by elimination of  a large  capacity  suction  fan.
 The total power consumption  is  only  5 - 10  % of  that needed  for the  system
 with forced  suction  and  bag-house,  even  estimated  from  a   very   moderate
 assumption  that the  dirty gas  volume  to  be  handled is  the  same  for  both
 cases.   Actually,  however, the  gas volume  to be  treated by REP  is  only  the
 net gas  volume  of dirty  gas  automatically  subjecting  to  a thermal lift.
 Whereas,  in the latter case, a  large  quantity of ambient air  is inevitably
 mixed  to the  hot  dirty gas,  so that  the  total  gas volume to  be  suctioned
 becomes  enormous,  amounting to  1.5  - 2.5  times the actual dirty gas volume.

    The  second of  additional  advantages is its noiseless character  also due
 to  the elimination of  the suction fan.    As a  result of  these remarkable
 merits   REP has   been  very  positively  accepted  by  the  iron  and  steel
 industries  in Japan for fugitive emission control.

    The major manufacturer of REP  is  SUMITOMO HEAVY INDUSTRIES,  LTD.(SHI)
 but  SUMITOMO  METAL 4  MINING CO.,  LTD.(SMM), HITACHI  PLANT  ENGINEERING 4
 CONSTRUCTION CO.,  LTD.(HPC),  and CHIYODA CHEMICAL ENGINEERING  CO.,  LTD.  are
also  sharing  to  the REP  market.     The total number of REP's  installed by
March 1980  is  at  least 38  units with  9 units for converter shops,  7 units
for casting floors  of  blast furnaces,  and  22  units  for electric  furnaces of
various types.

    In this  paper  is  reported the  present  status  of the  ROOF MOUNTED TYPE
ESP's for  fugitive emission  control  in the  iron and  steel   industries  in
Japan.
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1. Introduction

    The ROOF MONTED TYPE  ESP  (REP:  ref.  (1)  -  (7))  has aquired,  since  its
first  installation  in March,  1972 at a  steel  converter shop  (3 units x  80
tons;  KOBE  WORKS  of KOBE STEEL  CORPORATION,  LTD.),  an  established  position
in  the Japanese  iron  and  steel  industries  for the   control  of  fugitive
emissions at various  workshops  including converter shops, catsing  floors  of
blast  furnaces, and electric furnaces,  A light-weight ESP is  mounted  on  top
of the roof of a workshop, and  the  dirty hot gas emited from  its  sources  is
passed through  this ESP by the action of  its  thermal draft  without the  aid
of a suction fan.  The first aim of considering this  technology  was  to solve
the  problem of  a  limited  site  for  installation of   a  conventional dust
collecting  facility.     However,  after  its  start  of  operation  a   quite
remarkable  advantage  of  REP in its  inherent energy  saving  character  has
become clear.  This  is because it does not  use a large capacity  induced  fan
which,  otherweise,  has  to suction the  hot dirty  gas plus  a  substantial
quantity  of surrounding  air  against  a  high  pressure  drop  of  a gas  duct
system (150 - 250 mm  H-0)  and a bag filter  (150  - 200 mm H^O).    The total
gas volume  to be handled  in the  forced suction system amounts to  as high as
1.5  - 2.5  times that of  the  actual  dirty  gas (5).     In  addition,  its
noiseless feature resulted  by elimination of  the  fan also provides a large
merit.

    As a result REP's  are being used  in increasing  number  in  the  iron  and
steel  industries  in  Japan,  amounting to as  many as  at least  38 units  in
total  at  the  end of March, 1980: 9 units for  converter shops,  7  units  for
casting  floors  of  blast  furnaces,   and  22  units for  electric   furnaces  of
different kinds.    The largest  share-holder among  the manufacturers  of  REP
in Japan  is SUMITOMO HEAVY INDUSTRIES,  LTD.(SHI),  whereas SUMITOMO METAL &
MINING CO.,  LTD.(SMM),  HITACHI   PLANT ENGINEERING  &  CONSTRUCTION  CO.,
LTD.(HPC) and  CHIYODA CHEMICAL ENGINEERING CO.,  LTD.  are  also manufacturing
REP's.

    In this paper is  reported the  present  status of the ROOF  MOUNTED TYPE
ESP's  in  Japan as applied in  the  iron  and  steel industries,  including  its
construction,   design  problems,   application   fields,   and  its  specific
advantages, together with its operation  data.
2. Construction

    Fig.  1 illustrates  a  system of  the  fugitive emission  control equipped
with REP.  There are slight differences in the  construction  of REP depending
upon the difference in manufacturer's design  concept  and specific conditions
of indivisual applications.

   Figs. 2 illustrate the construction of SHI-type REP,  and  Fig.  3 shows its
photograph taken from outside.   A light-weight ESP is mounted  on top of the
roof of a workshop above the emission sources.
   The collecting electrodes are out of thin  stainless-steel plates,  and the
discharge   electrodes   are  stainless-steel   wires   or   round  piano-wires
supported  by  metal  frames.   The  use  of  the  frame construction provides
advantages  in light-weight and ease of centering.    No thermal deformation


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 occurs in this  particular  case as  the gas  temperature  at the  precipitator
 inlet is below 80 (deg C) (typically 40 - 60 deg C).
      The  whole  electrode system  is mounted  inside  a  light-weight  housing
 having no roof  on  its top.   The  shell of  the  housing  is  out  of a  special
 laminated plate consisting  of a thin steel plate covered with plastic  layers
 so  that  sufficient  durability  can  be  obtained  against  corrosion   and
 weathering in spite of its  small thickness.
    The precipitator is of a  semi-wet type with both collecting and discharge
 electrodes being intermittently cleaned by  water  spray.   The whole REP  unit
 is devided into a  number of blocks, and washing  is made  block  by  block.
 Each block is  washed  1-4 times,  a  day, each  time  for _10  minutes  with  a
 water feed  rate of 0.1  -  0.6  (m /min)  (typically  0.4 m /min).     So,   the
 water  feed   rate  needed  is  independent of  REP  capacity,  and  the  total
 quantity of  spray water to  be supplied  per day is  very small,  and  given by

         Qw - (0.1 - 0.6 m3/min)  x  (10 min) x Nb  x  Nw     (m3/d)           (i)

 where  Nb «  number  of  blocks,  and   Nw = number of washing  per day.  The use
 of this  semi-wet design provides  the  advantages such that  both  the  back
 discharge due  to high resistivity  dust and  the  dust reentrainment  due  to
 mechanical rapping   are effectively avoided,  that  the  noise  and vibration
 problem in rapping  operation is solved,  and that  elimination of  the  rapping
 system with  many moving parts  contributes  to  the  light-weight  scheme  and
 ease in  maintenance.   In addition,  the semi-wet scheme  combined with   the
 open housing construction contributes much to  avoid  a  danger of explosion  to
 be caused by coal dust and carbon  monooxide.
     The slurry  is  collected by a louver-shaped  hopper  located  under  each
 block,  and fed through troughs to a conventional  water  treatment system,  as
 indicated  in Fig. 4.   A portion of clear water  is reused  for spraying after
 pH-adjustment.
    The hot  dirty gas  from  the emission sources  rises with its thermal  lift
 up to the top  of the  workshop, and  enters  through the  louver-hoppers  into
 the collection field of  each block  of  REP.    The  louver-hoppers  serve as a
 gas distributer  to equalize  the   gas   velocity.      The   gas flows   upward
 vertically through   the  collecting ducts, and  is  emited directly into  open
 air from  the  top of  REP.
    The insulators supporting the  frames of  discharge  electrodes  are encased
 in the insulator boxes located on  top  of  the REP housing,  and clean  air  is
 purged  into  the  boxes  to  prevent contamination of  the insulators.
    A  high voltage power-pack with automatic voltage control is  also mounted
 on top of  the  roof  of  the workshop.
     Table  1  indicates  an   example  of  the  design  data  of  a SHI-type  REP
 installed  at a  converter  plant.

    Figs. 5 shows a photograph of the  SMM-type  REP.    In the SMM  design,  the
 hot dirty  gas  is at  first gathered in a  monitor, and,  then,  fed horizontally
 to REP mounted on top  of  the workshop roof adjacent to the  monitor (Fig.  6).
A  number of  low-power  roof-fans  are installed at  the  outlet  of  the SMM-type
REP to suction  the gas horizontally through its collection field.    Both  the
dry-type and wet-type REP's are manufactured by SMM.
   The details of the constructions of REP's of  SMM  and  other manufactureres
are not much ifferent  from that  of SHI, so  that the further descriptions of
each design are omitted.
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 3. Design  Problems

   There are  several  problems  to be carefully  considered  in the planning and
 design  of  REP.   These  are the estimation  of gas  volume  to  be  handled by
 REP,  the  properties  of  dust   to  be  collected,  the  location  of  REP  with
 respect  to the number and  position of  emission sources,  and  prediction of
 wind.


 3-1) Calculation of Gas Volume:

      The  ascending speed of hot dirty gas  from  emssion  sources lowers with
 height because of the decrease  in its  temperature due  to  mixing with ambient
 air.    Its final speed  at  the  inlet  of REP  depends  upon the  roof  height,
 building volume  and shape of  the  workshop as  well  as the number,  capacity
 and operating conditions  of  the emission sources.    As  a  result, an accurate
 estimation of the  gas volume  to  be handled  by REP is  extremely difficult,
 and requires  much experience.
   In  the  case when  REP is to be installed on  an  existing  workshop,  it is
 imperative to directly   measure  the   gas  volume  in  advance  by  measureing
 velocity   distribution  of   gas  at  each  monitor   under  various  operating
 conditions.    The measurement  of  dust loading must  also  be performed  at the
 monitor.
    In the  case when  REP  is to be  installed on  a  new plant,  the following
 theoretical gas volume, Qz,  used for design of a  canopy hood  provides  a clue
 for the gas volume estimation of REP (see Fig. 7):

        Qz  -  1.95 x Z3/2  x  (H')1/3           (m3/min)                    (2)

        H'  =  (1.45/60) x  As x T4/3           (kcal/min)                  (3)

where  Z = height of REP  inlet from provisional position  of heat source (m),
H1 " heat  transmission of convection  current  fronu heat  source  (kcal/min),
As "  surface  area  of heat  source  -  ( 77/4)  x Do   (m ),   T  = temperature
difference between heat source and ambient (deg C).
   The actual gas volume  to  be handled, Q, can  be estimated by multiplying a
correction factor, K, as:

        Q  - K x Qz                           (m /min)                    (4)

The correction factor should be selected  in the  range of   K  = 1.5 -  2.5
from the experience at the similar installations.
   Fig. 7  is  a chart for  estimation of Qz  as a function of H  and  Do  for the
case when  Z = H + 2 Do (4).


3-2) Dust  Properties:

    The mass-loading,  particle  size  distribution, chemical composition, and
electrical  resistivity of the  dust to be handled by  REP  must  be carefully
studied.     The inlet  mass-loading   of  dust  determines  the  quantity and
frequency  of  water spraying and the capacity of water  treatment  system.    In
most cases, however, the  inlet mass-loading of dust  hardly  exceeds the  level
of 1 (g/Nm3).

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     The frequency  of  water spraying  must be  raised  for fine  particles  in
 order to avoid the dust  reentrainment.   Table 2  gives the  examples  of the
 particle size  distribution  of  converter dusts  in Japan.
    The  chemical  composition  of dust may affect the design  of pH-adjustment
 system  for  slurry treatment,  the  corrosion  of  electrodes,  hoppers  and  a
 piping system of  REP,  and probably the  electrical resistivity  of dust.
 Table 3 provides  the chemical  composition  of the dusts  indicated in Table 2.
    The electrical  resistivity  of  dust may become very high  at  60 - 90  (deg
 C)  to be encountered at  the  inlet of REP, as  shown  in Table  4.     Then,  a
 severe back discharge  may  occur  in the   collection  field of  REP  when the
 quantity and  frequency  of water spraying  is insufficient  or  the water  spray
 system fails.


 3-3)  Location  of REP:

    From an economical point of view  REP should be located  only  at  an area at
 which dirty hot  gas  arrives.      The location  of REP  must  be  determined,
 considering  the  thermal  current  of  the  dirty  gas,  its  diffusion and the
 effect of wind.
4. Applications
4-1) Converter Shop

   In this application the dirty gas volume is very large, so  that  its total
quantity is handled only by REP.    The fluctuations  in  gas  temperature,  gas
velocity  and dust  loading at  the  inlet of  REP  are  very  large  in  this
application.  Table  5 gives some of  the  design and  operation data  in  this
application.


4-2) Casting Floor of Blast furnace

    Again in this application the whole dirty gas  is  handled  solely  by  REP
because of its very large volume.
4-3) Electric Furnace

    In  this  application REP  is used  either alone  or  in combination  with
monitors, depending upon the workshop  conditions.    The fluctuations  in gas
temperature,  gas velocity and  dust loading  at  the REP  inlet  are also  very
large.    Table 6  provides  again some of  the design  and  operation data  in
this application.
5. Advantages of ROOF MOUNTED TYPE ESP's
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   REP's have the following inherent advantages:

(1) Saving of installation site.
(2) Stable operation and high collection performance.:
   This is resulted by the semi-wet operation scheme where  no  back discharge
and dust reentrainment take place.
(3) Low installation costs:
     The installation  costs may  become  rather lower  than the  alternative
emission control  system using  forced  suction  and  bag-house because of  the
simple  light-weight  construction of  REP as  well  as the  elimination  of  a
large suction fan and a gas duct system..
(3) Very low power consumption:
    The total electric  power consumption of  REP is  only  5 -  10 % of  that
needed for the system using forced suction and bag-house.    This  is resulted
by the eliminations of a large  induced  fan  which has to suction  a large  gas
volume against  the  pressure drops at canopy  hoods,  gas duct  (150 - 250  mm
H90)  and  filter bags  (150 -  200  mm H^O).     The  pressure drop  of REP  is
almost the same as that of monitors.  Tnis figure of energy  saving is a  very
moderate estimation assuming the gas volume to be the same for  both  cases.
However, the  actual  gas volume to be handled in the latter case  amounts  to
1.5 - 2.5  times  that  of  REP  which selectively  handles the  hot dirty  gas
ascending by its inherent thermal lift.
(4) Operation without noise and vibrations.
(5) Low maintenance costs:
   The maintence costs of REP are very small because  it  does not  require  the
exchange of bags and moving parts, and its water consumption is also small.
The amount of water feed rate  needed for electrode  spraying  is   only 0.1 -
0.6 m /min, and  the used water is  recycled  after slurry treatment.    As a
result the amont  of water for  replenishment  is little.     In  addition,  the
maintenance work is hardly needed because of  its simple construction without
moving parts.
6. Energy Saving Feature of ROOF MOUNTED TYPE ESP's

     As  the  contribution of  REP  to  enery  saving is  quite  remarkable,  it
deserves  a  special  investigation.    A  comparison  is made  of  the  power
consumption  for the  respective  applications  between  a  REP  system and  a
conventional  system with  forced  suction  and  bag-house  (7).     The  power
consumption of  the  REP systems is taken from  the practical operation data,
whereas  those  of  the  systems  with  forced   suction and  bag-house  are
calculated based on the same gas volume as previously described.    Tables 7
g  and  9    show respectively  such a comparison  in  the  applications for  a
converter shop,  a  casting floor of blast  furnace and an  electric  furnace.
It may be well understood that the contribution of REP  to  energy saving must
be given a special attention.

   The case studies  of comparison are further made between  the  two systems,
considering all  the  power consumption needed not  only  for operation of each
dust  collecting equipment,  but  also for  production  of  all the  materials
necessary  to  construct each  equipment  (7).    The calculated  result for  a
standard 30 ton/ch. electric  furnace  is given in  Table 10  ,  whereas that for
a  standard  160  ton/ch. converter  in  Table 11 .     These results reveal  that


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 the saving of eneijgy  resulted by the use of  REP  amounts in ten years  to  as
 high as 188.8 x  10  (kcal) in the former case  and  350.4 x 10  (kcal)  in  the
 latter case.   Based on these data the  study  is extended to all  the  electric
 furnaces and  converters existing in  Japan in December,  1976 (Table 12).   The
 saving to be  obtained  by using  REP's  in ten  years in  all  of  the  electric
 furnaces will amount  to. as high  as 68.5 x  10   (kcal), while  that  in  the
 converters to 32.2 x  10    (kcal).   This energy saving  corresponds  to ca.  1
 million tons  of  crude  oil per year.
 7.  Conclusion

    The  present status  of ROOF MOUNTED TYPE  ESP's  in Japanese iron and  steel
 industries  is described.    The  conclusions of  this  parer are  as follows:

 (1)  REP's  have  aquired an  established  position  in  the  Japanese  iron and
 steel industries.

 (2)  REP's  have  a number  of  inherent advantages  over a system  with forced
 suction and  bag-house.   These  are  (a)  saving in  installation  site,  (b)
 stable  operation  and  high collection   performance,  (c)   very  small   power
 consumption,  (d) low  initial  and maintenance  costs, (e)   operation without
 noise and vibration, etc.

    It  is likely that  ROOF MOUNTED TYPE  ESP's  will be more extensively used
 in  future  in Japan, not only  in the  iron and  steel  industries  but  also  in
 the  other  industrial fields, primarily  because  of  its very remarkable merit
 of energy saving.
                                  Reference

 (1)  Teruo  WATANABE:  Electric Precipitator on  Roof to Prevent  Emission Dust
 from  Shop  Housing,  Jounal of Powder Engineering  Research  Association Japan
 Vol. 9, No. 6, pp. 418 - 421 (1972).
 (2) Masakazu  SAKAI:  Roof-Mounted Type Electrostatic  Precipitator,  Technical
 Journal of SUMITOMO HEAVY INDUSTRIES, Vol. 22, No. 65 (Aug., 1974).
 (3) Tsutomu NOMURA and Masakazu  SAKAI:  Roof-Mounted  Electrostatic Precipita-
 tor  for  Casting  Floor  of  Blast  Furnace,  Proceedings  of  Institute  of
 Electrostatics Japan, Vol. 1, No.2, pp. 82 - 87 (1977).
 (4)  SUMITOMO  HEAVY  INDUSTRIES,  LTD.:  R.  Ep.  -  Roof-mounted  Electrostatic
 Precipitator, Technical Report of SHI (Oct., 1977).
 (5) Shoji ITO, Shigeyuki NOSO, Masakazu SAKAI and Kiyoshi SAKAI:
 Roof-Mounted  Electrostatic  Precipitator,  Proc.  of  1st  EPA-Symposium  on
Transfer and  Utilization  of  Particulate Control Technology, Vol.  1,  pp.  435
- 495 (July, 1978 in Denver).
 (6) Ken TAKIMOTO: Wide-Spacing EP  Is Available in Cleaning Exhaust  Gas from
 Industrial Sources,  Proc.  of 1st EPA-Symposium  on Transfer and  Utilization
 of Particulate  Control Technology,  Vol.  1, pp.  297  -  305  (July,   1978  in
Denver).
 (7) Shigeyuki NOSO, Masakazu SAKAI and Toru SASAKI: Roof-Mounted Electrostat-
 ic  Precipitator   Saving   Energy,   Technical   Journal  of  SUMITOMO  HEAVY
 INDUSTRIES, LTD., Vol. 26, No. 78,  pp. 75 - 78 (Dec.  1978).


                                     312

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           Table 1    Design Data of SHI-Type REP for Converter
 1.  Dimension
 2.  Casing
 3.  Collecting Electrodes
 4.  Discharge Electrodes
 5.  Power Consumption

 6.  Water Feed Rate
 7.  Gas Volume
 8.  Gas Temperature
 9.  Inlet Dust Loading
10.  Outlet Dust Loading
4800 mm height x 6800 mm width x 50000 nm length
# 24 color steel plate
stainless-steel plate
stainless-steel wires supported by steel  frames
high voltage power pack: 90 kw
motors, etc.:             11 kw
0.6 m3/min. (intermittent cleaning)
17100 - 27800 m3/min.
35 deg C
0.270 g/Nm3
0.047 g/Nm3
           Table 2   Example of Particle Size Distribution of Converter Dust
*^\^
A Co.
B Co.
C Co.
^ 10 urn
15.5
4
13.5
10 ^ 20 pm
19.5
11
30.5
20 % 50 ym
50
53
42.0
50 urn ^
11
32
14.0
true specific
.gravi ty
3.49
4.27
3.94
           Table 3   Results of Chemical Analysis of Converter Dust

A Co.
B Co.
C Co.
T. Fe
29.6
45.07
32.92
Si02
8.5
8.76
6.92
A12°3
3.35
3.30
2.50
T. S
1.1
0.154
1.23
MgO
1.45
1.32
5.57
Na20
1.65
0.32
0.57
K20
0.17
0.17
0.16
CaO ZnO
22.85 0.
8.91 1.
13.88 0.
PbO
7 0.
99 0.
57 0.
T.C
15 4.85
36 9.93
09 2.16
MiO MnO
-
0.02 -
- 4.44
           Table 4   Electrical Resistivity of Converter Dust
^\^
A Co.
B Co.
C Co.
30 deg C
6.78 x 10^1 n-cm
5.3 x 105 n-cm
7.31 x 1012 n-cm
60 deg C
6.83 x 1012 n-cm
9.6 x 105 n-cm
9.11 x 1012 si-cm
90 deg C
1.04 x 1Q13 fl-cm
5 x 10 6 fi-cm
1.07 x 1013 n-cm
difficulty in
collection
normal
easy
normal
                                       313

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                Table  5    Design  and  Operation  Data  of REP  for Converter Shop
Installations
A
B
C
D
Design
Actual
Design
Actual
Design
Actual
Design
Actual
Total
Gas Vol.
m /min
24000
13600-
28600
43800
51000
30900
42400
27000
9800-
22800
Gas Vol. per
Converter
m /min
8000
4500-
9500
14600
17000
7700
10600
13500
4900-
11400
Gas Vel .
m/s
1.77
1.0-2.1
1.78
1.9
0.8
1.1
1.66
0.6-1.4
Inlet
Dust
Loading
q/Nm3
0.1
0.269
(max. )
0.4
0.33
0.4
0.35
0.4
1.09
(max.)
Outlet
Dust
Loading
q/Nm3
0.02
0.047
0.03
0.02
0.02
0.02
0.03
0.038
_
Remarks
LD
80 t/ch.x 3
LD 250 t/ch.
x 3
LD 160 t/ch.
x 3
Q-BOP 230 t/
ch. x 2
Remarks: SHI-Type  REP's
               Table 6   Design and Operation Data of REP for Electric  Furnace
Installations
A
B
C
D
Design
Actual
Design
Actual
Design
Actual
Design
Actual
Total
Gas Vol.
m /min
8200
10700
4900
4600
5600
6800-
9000
4000
3700
Gas Vol. per
Electric F.
m /min
8200
10700
4900
4600
2800
3400-
4500
2000
1950
Gas Vel.
m/s
1.0
1.3
1.0
0.94
1.0
1.2-1.6
1.0
0.92
Inlet
Oust
Loadina
q/Nm3
0.2
0.2-0.4
0.3
0.15-0.29
0.3
0.16-0.42
0.3
0.1-0.16
Outlet
Dust
Loading
g/Nm3
0.02
0.01-0.03
0.03
0.01-0.02
0.03
0.01-0.03
0.03
0.01-0.015
Remarks
100 t/ch
x 1
,.,
30 t/ch.
x 1
•
18 t/ch.
x 2
• —
8 t/ch.
x 2
Remarks: SHI-Type REP's,
                                      314

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Table 7
Comparison of Power Consumption between  REP and Bag-House
      (Converter Shop)
x
A Co.
B Co.
C Co.
D Co.
Gas Volume
3
(m /min)
24000
43800
30900
27000
Power Consumption (kw)
Bag-House
2800
5100
3600
3100
REP
41
150
170
90
Table 8
Comparison of Power Consumption between REP and Bag-House
      (Casting Floor of Blast Furnace)
\
A Co.
Gas Volume
(m /min)
35000
Power Consumption (kw)
Ban-House
3500
REP
240
Table 9
Comparison of Power Consumption between REP and Bag-House
      (Electric Furnace Shop)
\
A Co.
B Co.
C Co.
D Co.
E Co.
F Co.
G Co.
H Co.
I Co.
J Co.
Gas Volume
2
(m /min)
4000
8200
4900
2440
5600
2670
2450
1100
1400
38000
Power Consumption (kw)
Bag-'House
930
1900
1120
560
1290
620
560
1250
1250
8750
REP
50
100
63
40
38
40
45
25
35
330
                            315

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 Table  10    Comparison  of Total  Energy Consumed  in  Ten  Years
            in  Case  A Bag-House  Is  Replaced  by REP

                   (30  t/ch.  Electric  Furnace)
\^
Power Consumption
Production of Materials
Item
High Voltage
Powtr Supply
Suction Fan
Accessories
Total
Steel
(85 t)
Collector 	
Plastics
(13 t)
Steel for Reinforce-
ment- of Roof (39t)
Total
Bag-House
—
1100kwx7200h/yxlOy =
79,200,000 kw
10kwx7200h/yxlOy =
720,000 kw
79,920,000 kwh =
195.8 x 109 kcal
—
•
-
-
REP
10.7kwx7200h/yxlOy =
770,400 kwh

20kwx7200h/yxlOy =
1,440,000 kw
2.210,4000 kwh =
5.4 x 109 kcal
85txll.2xlOt)kcal/t=
952x1 O6 kcal
13txl3.0xlObkcal/t =
Ibyxlu6 kcal
39txll.2xl06kcal/t=
437x1 O6 kcal
1,558 x 106 kcal
Table 12   Number and Nominal Capacity of Electric Furnaces and
           Converters in Japan (Dec. 1976)
Electric Furnace
Nominal Capacity (t)
5 - 18
20 - 35
40 - 60
70 -
Aver. Norn. Cap.
27 t
Number
185
92
73
28
Total
378
Converter
Nominal Capacity (t)
40 - 90
100 - 180
200 - 270
300 -
Aver. Norn. Cap.
152 t
Number
38
34
25
7
Total
104
                                316

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Table 11   Comparison of Total Energy Consumption in Ten Years
           between Bag-House and REP
                  (160 t/ch. Converter)

Power Consumption
Production of Materials
Item
High Voltage
Power Supply
Suction Fan
Accessories
Total
Collector

Steel
Plastics
Suction Fan & Duct
System (126 t)
Steel for Reinforce-
ment of Roof (54 t)
Concrete (125 m3)
Total

Bag-House
—
1700kwx8400h/yxlOy =
142. 8x1 O6 kw
20kwx8400h/yxlOy =
1.63xl06 kw
144. 48x1 O6 kw =
354x1 O9 kcal
450txll.2xT06kcal/t =
5,040xl06 kcal
24txl3x106kcal/t =
312xl06 kcal
126txll.2xl06kcal/t =
I,411.2x106 kcal
-
125ra3x4.8xl06kcal/m3 =
600x1 O6 kcal
7,363.2xl06 kcal
REP
23kwx8400h/yxlOy =
1.9 32x1 O6 kw
—
20kwx8400h/yxlOy =
1.63xl06 kw
3. 61 2x1 O6 kw
8.8xl09 kcal
115txll.2xl06kcal/t =
1, 288x1 O6 kcal
20txl3xl06kcal/t =
260x1 O6 kcal
.
54txll.2xl06kcal/t =
604. 8x1 O6 kcal
-
2,152.8xl06 kcal
                               317

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                          t
       MATER  SUPPLY
                             REP
       WATER TREATMENT

'/////s/////////
                                                 BAG  FILTER
           Fin. 1    System  of ROOF MOUNTED TYPE ESP
                                       t
               Witer supply unit
       Insulator ehtmbir
       Spray norilt

           Curtain
                                                           Drain
                                                  Detail of Hopper
F1g.  2    Construction of ROOF-MOUNTED TYPE ELECTROSTATIC
          PRECIPITATOR (SHI-Type)
                                   313

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   Fig.  3    ROOF-MOUNTED TYPE ESP  for Converter Shop
                       (SHI-Type)
 1   waste water
                                               11
                               9       10
                                 2  chemical  additive (pH-control)
3  stroage and neutralization    4  sedimentation  tank
   tank
5  chemical additive
7  recycling water for spray
 9  sludge storage tank
11 cake
 6  netralization tank
 8  final  effluent
10  hydroextractor
       Fig.  4   Waste Mater Treatment for REP
                                319

-------
  Fig. 5    ROOF-MOUNTED TYPE ESP  (SMM-Type)
                   CLEAN GAS
GAS CONTROL VANE
                                                       MONITOR
                       COLLECTING ELECTRODE
                          DISCHARGE ELECTRODE
                               WORKSHOP
 Fig.  6   Construction of  ROOF-MOUNTED TYPE ESP  (SMM-Type)

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£ 15,000 •
 E
 N
cr
i  10,000
(O
CJ
^   5,000
u

-------
                    FUGITIVE HYDROCARBON EMISSIONS FROM AN
                           IN-SITU OIL SHALE RETORT

                   Gerald M. Rinaldi and David R. Tierney*
                        Monsanto Research Corporation
                              Station B, Box 8
                             Dayton, Ohio 45407

Oil shale has been recognized as a potentially substantial energy resource in
the United States for more than a century.  An emerging technology for shale
oil production is in-situ processing, in which the shale bed is hydraulically
or explosively fractured and retorting is carried out underground.  In order
to assess potential environmental impacts from in-situ processing, data were
collected on fugitive emissions from a pilot-scale retort producing 30 barrels
of crude shale oil daily.  Fugitive gas seepage through the retort surface and
from around instrumentation well casings was measured using a specially designed
sampling system in conjunction with gas chromatographic and Orsat analysis.
Total hydrocarbons, Ci through C6 hydrocarbon fractions, and carbon monoxide
were quantified in the fugitive emission samples.  Normalized fugitive hydro-
carbon emission rates due to seepage through the overburden ranged from 0.2 to
18 g/m2/hr, with an average of 5.5 g/m2/hr.   The total hydrocarbon emission rate
due to ground seepage was calculated to be 5.7 kg/hr, using the retort surface
area of 1,043 m2; fugitive hydrocarbon emissions due to leakage around well
casings amounted to an additional 0.3 kg/hr.
             *Present Address: Clarkson College of Technology,
                            Potsdam, New York.
                                      322

-------
                   FUGITIVE HYDROCARBON EMISSIONS FROM AN
                          IN-SITU OIL SHALE RETORT

                                 Introduction

Oil shale has been recognized as a potentially substantial energy resource in
the United States for more than 100 years.  Rapidly escalating oil prices have
provided new incentive for shale oil recovery from deposits in Colorado,  Utah,
and Wyoming.  At least four U.S. firms (Colony Development Operation,  Paraho
Development Corporation, Superior Oil Company, and Union Oil Company)  have
developed surface retorting processes, in which oil shale is mined and crushed
prior to thermal processing in above-ground facilities.  The costs associated
with mining and handling voluminous quantities of raw shale and the environ-
mental impact of spent shale disposal may limit commercial application of this
technology.1  Therefore, a good deal of research is currently being directed
toward the development of in-situ or modified in-situ retorting processes.
This technology, in which the shale bed is hydraulically or explosively frac-
tured and retorting is carried out underground, may offer a cost-effective solu-
tion to the shale handling and disposal problems associated with surface
retorting.1  In-situ or modified in-situ processes are now being developed by
Equity Oil Company, Geokinetics, Inc., Rio Blanco Oil Shale Company, and
Occidental Oil Shale, Inc.

Since in-situ oil shale retorting is an emerging energy technology, its poten-
tial environmental impacts are largely unknown.  Under Contract No. 68-03-2550
for the U.S. .Environmental Protection Agency  (EPA), a field sampling program
was conducted to identify and quantify emissions and effluents resulting from
horizontal in-situ oil shale retorting.  The  technical description and results
presented herein are concerned only with the measurement of fugitive emissions
from a pilot-scale retort, located on the Kamp Kerogen site in Uintah County,
Utah, and operated by Geokinetics, Inc.  The  shale bed was rubblized in May
1978 and ignited in April 1979; field sampling was conducted from July 16 to
July 26, during which time the crude shale oil production rate was approxi-
mately 30 barrels per day.

The Geokinetics horizontal in-situ retorting  process begins with the drilling
of blast holes from the surface, through a maximum of 46 m of overburden, and
into the oil shale bed.2  The holes are then  loaded with explosives, which
are fired to yield a rubblized mass of oil shale with  increased permeability.
During fragmentation, the surface undergoes noticeable uplift.  A slope  is
created below the oil shale bed, allowing shale oil to drain to a sump for
recovery by production wells, as shown in Figure  1.
                                      323

-------
AIR INJECTION WQi
    LIQUID
PRODUCTION WELL





                                                                                              RETORT
                                                                                            •OFF-GASES
                                                                                           OIL/WATER
                                                                                            MIXTURE
                                                                                  SUMP
  Figure 1.   Sectional view  of Geokinetics  horizontal in-situ oil shale retort.

-------
                             Experimental Methods

The uplift of the retort overburden, due to shale deposit fragmentation,
causes ground cracks of various sizes.  Plant personnel routinely seal major
cracks by filling with mud and tamping before retorting begins,  but escape  of
gases from the  burning retort is not entirely eliminated.   However,  because
it was Geokinetics' understanding that the purpose of this  fugitive emissions
study was characterization, not quantification, only those  leaks that presented
an obvious health hazard were sealed during the sampling period.  Additional
sources of fugitive emissions are created by drilling and casing instrumentation
wells into the oil shale bed.  It has been estimated that one-third to one-half
of the total volume of gas injected into the in-situ retort is not recovered at
the outlet wells.3  A 30 kw (40 hp) vacuum blower, capable  of reducing, if  not
altogether preventing, such gas seepage, was not in operation during the sampling
period.

In order to obtain representative data, test locations for fugitive gas samp-
ling were randomly selected, with the constraint that an approximately equal
number of sites be placed in each of four quadrants of the surface area of  the
retort.  Locations for sampling ground seepage were selected by using a random
number table corresponding to consecutively numbered squares on a grid super-
imposed over a scale diagram of the retort.  Twenty-seven of these potential
fugitive emission sources were tested, non-simultaneously,  along with six
thermocouple wells and one of two shale oil production wells.

The sample collection method used in this effort was developed by combining
the applicable features of techniques previously used extensively in the
measurement of fugitive emissions from sources as diverse as vegetation and
petrochemical processing equipment.4'5  Prior  to sampling, selected test
locations were enclosed using an aluminum box, 0.61 m square, having an open top
and bottom.  The aluminum box was driven into  the soil and anchored at all four
corners with metal rods; moist soil was used outside the bottom of the sampling
box to provide a seal to the retort surface.   The top of the box was covered with
flexible plastic, attached to the sides by duct tape.

Figure 2 is a schematic diagram of  the fugitive emission sampling system
used at the Geokinetics1 oil shale  retort.  The sample box outlet was
connected, via a three-way valve, to a 500-mL  glass syringe and to a vacuum
pump.  For approximately five minutes prior to sample collection, the pump
was used to evacuate the sample box, after which the pump was disconnected
and replaced with a Teflon sample bag.  The three-way valve was then adjusted
so as to seal the sample box off from both the syringe and the  sample bag.
The aluminum box was next filled with "zero-grade" air from a pressurized
cylinder at a measured rate of 10 liters per minute, causing  the plastic cover
sheet to rise.  When the box was partially inflated, a sample was obtained
by using the syringe to withdraw a  portion of  the gas containing fugitive
emissions and, after turning the three-way valve, to inject this into  a Teflon
bag.  Field "blanks", consisting of samples of zero-grade air which were
                                       325

-------
Ul
NJ
Al
REGUL
1=3 GX
n
R 1
ATOR |
? u
I) 1 » 1
1
\^4
ORIFICE 'T
METER
AIR ROW
/'CONTROL VALVE
1
\
w.
MANOM




ETER
1
L|
I
i
1 FLEXIBLE
PLASTIC COVER
A/ A
"N 	 /
SAMPLE BOX
ZERO-GRADE ^ RETORT SURFACE
IR CYLINDER
3-WAY
VALVE
A
1_
500 ml SYRINGE
... J I i
1 	 1 '
_ / /^AMPIFRAft
-•Q— ^^
VACUUM
PUMP
                                    Figure 2.   Fugitive  emission sampling system.

-------
passed through the flow control valves, the orifice meter,  and all connecting
lines, but not the sample box, were also collected using the glass syringe
and Teflon bags.

Samples contained in the Teflon bags were analyzed on-site  for total hydro-
carbons and GI through Cg hydrocarbon fractions using a portable gas chromato-
graph with a flame ionization detector.  Selected fugitive  emission samples
were also tested for carbon dioxide (C02), carbon monoxide  (CO), and oxygen
(02) by Orsat analysis.

                                    Results

The rates of fugitive gas seepage from the retort surface and from around well
casings were determined using the following equation, which is based on the ideal
gas law (and which includes a numerical constant accounting for conversion of
mm Hg to atmospheres, liters to cm3, and minutes to hours):

                    E = 7.895 X 10"5 HP  G(C  - C, )/RT                    (1)
                                        S    S    D    S

where  E  = fugitive emission rate, g/hr
       M  = molecular weight of emitted material, g/g-mole
       Ps = atmospheric pressure during sampling, mm Hg
       G  = cylinder gas flow rate, liters/min
       C_ = concentration in sample bag, ppm
           = concentration in field blank, ppm
           = ideal gas constant =82.1  cm3«atm/g-mole*  °K
       T  = ambient temperature during sampling, °K

The calculated hydrocarbon emission rates for tested sources  are  given  in
Table I.  Emission rates for ground seepage sources were normalized by
dividing by the cross-sectional area of the sample box, equal to  0.37 m2.

The average hydrocarbon emission rate  for ground seepage was  5.5  g/m2/hr,
with  a range of 0.2 to 18 g/m2/hr.  In Figure 3, the distribution of measured
hydrocarbon emission rates over the surface of the retort  is  shown.  The  total
fugitive hydrocarbon emission rate of  6.0 kg/hr  was calculated by adding  the
product of the  average ground seepage  rate  (5.5  g/m2/hr) and  the  retort surface
area  (1,043 m2) to product of the  average emission rate  from  wells (5.3 g/hr)
and the total number of wells  (46).

Additional analyses were conducted to  determine  the  general composition of
hydrocarbons in the fugitive  emission  samples.   Table  II gives the concentra-
tions of G! through C6 hydrocarbon fractions for selected  bag samples.  Orsat
analyses of selected samples  are given in Table  III.
                                       327

-------
                 Table  I.    Fugitive  hydrocarbon emission rates.'
Sample type
and
run number
Ground seepage:
G-l
G-2
G-3
G-4
G-5
G-6
G-7
G-8
G-9
G-10
G-ll
G-12
G-13
G-14
G-15
G-16
G-17
G-18
G-19
G-20
G-21
Hydrocarbon
emission rate
g/m2/nr

2.9
0.4
14
11
15
5.7
°'3b
0.7D
3.4
6.8
18
10
5.6
7.0
1.6
0.9
8.5
4.9
2.4
0.3
0.2
Sample type Hydrocarbon
and emission rate,
run number g/m2/hr
Ground seepage
(continued):
G-22
G-23
G-24
G-25
G-26
G-27

Liquid produc-
tion well:
P-l

Thermocouple
wells:
T-l
T-2
T-3
T-4
T-5
T-6



0.5
3.3
7.0
2.9
8.0
2.4



7.8b



c
4-8n
3-7?
6-*H
5-4n
3.1b

     Emission rates per unit area determined by dividing hourly rate by
     sample box area of 0.37 m2.

     Emission rate given in g/hr (sample box not used).

    thermocouple well sample No. T-l was not analyzed.

                                  Discussion

The total fugitive hydrocarbon emission rate of 6.0 kg/hr is significant when
compared to the 17 to 19 kg/hr of hydrocarbon vapors contained in the retort's
off-gas outlet wells, the latter quantities having been determined in the
overall study of Geokinetics1 technology.6  In order to make a preliminary
assessment of the impact of fugitive hydrocarbon emissions on ambient air
quality in the vicinity of retort, dispersion modeling, according to the
method of Turner,7 was used to calculate ground-level hydrocarbon concentra-
tions.  The following assumptions were made:  1) the emissions originate from
                                      328

-------
10

vO

D
O

O


»
k

9 • ; a
A / APPROXIMATE
| DIRECT ION OF / BURN FRONT
BURN FRONT / LOCATION
MOVEMENT /
m \
\ ^ o
\e °

>





o
                                                            ^RETORT BOUNDARY
                                 METERS
                                       H  SYMBOLS:
< 0. 5 g/m/hr
         «
0. 5 - 2. 5 g/m'/hr
i 6 - 5. 0 g/m/hr

5. 1 -
                                                                                    > 10 9/mZ/hr
                        Figure 3.   Pictorial representation of magnitude of  fugitive hydrocarbon

                                     emissions due to  seepage through retort surface.

-------
          Table II.  Concentrations of Ci-C6 hydrocarbon fractions
                     in selected fugitive emission samples.
        Sample type
            and
        run number
                    Concentration, ppmv
                C2
                             C6
      Ground seepage:
        G-4               1,700    360    100     20     50     5
        G-ll              2,900    650    240    160     90     8
        G-14              1,200    330    100     80     20     3
        G-17              1,700    480    190    110     50     7
        G-24              1,300    360    120    110     50     4

      Liquid produc-
        tion well:
        P-l                 740    240     90     40     20     1

      Thermocouple
        well:
        T-2                 810    200     60     50     20     3
       Table III.  Orsat analysis of selected fugitive emission samples.
M^ —— — •»_•• ^^^^^ ^.^^^ ^
Sample type
and
run number
Ground seepage:
G-93h
G-13a
G-183
G-24a
Concentration
Carbon
dioxide
(C02)
0.2
5.0
4.0
8.0
(dry basis)
Oxygen
(°2>
10.6
7.0
7.2
5.8
i , percent by volume
Carbon
monoxide
(CO)
1.0
1.1
0.8
0
Carbon monoxide
emission rate
q/m2/hr '
21
23
17
0
Thermocouple
  well:
  T-4b
3.6
7.4
1.8
Concentrations are averages of duplicate analyses of sample.
 Concentrations are averages of triplicate analyses of sample.
cEmission rate given in g/hr (sample box not used).
                                     330

-------
a "point source," not strictly correct in this case but proven by calculations
to be adequate for order-of-magnitude estimation,- 2) the atmospheric stability
is represented by Class C; and 3) the averaging time is three hours, that for
the ambient air quality guideline for hydrocarbons.  In addition, a wind speed of
3 m/s, equivalent to the national average but corrected from a height of 7 m to
1 m, was utilized.  The calculated results are meant to approximate concen-
trations, not to replace ambient air monitoring, because the accuracy of
Turner's method is limited to within a factor of two or three due to empirical
determination of dispersion constants.

Table IV is a matrix of downwind ground-level hydrocarbon concentrations
calculated using the total fugitive emission rate of 1.7 grams per second.
Assuming the "point source" of fugitive emissions is located at the mid-point
of the downwind boundary of the retort, Table IV indicates that, within a
limited area nearby, the hydrocarbon concentration exceeds the ambient air
quality guideline of 160 (jg/m3.  During the three-hour averaging time, this
phenomenon occurs only within approximately 20 meters of the "plume" center-
line and up to approximately 300 meters downwind of the retort.  Extrap-
olating from the pilot-scale retort to a commercial facility operated at a much
greater shale oil production rate, the mass flow rate of fugitive hydrocarbon
emissions is expected to be greater, and the ambient air quality effects
would thus extend to a larger area than that suggested by Table IV.

       Table IV.   Downwind ground-level concentrations due to fugitive
                   hydrocarbon emissions from Geokinetics retort.

Concentration3, (jq/m3
b
x,
meters
10
20
50
100
200
500
1,000
2,000


c



y, meters
0
69,000
20,000
3,700
1,100
300
60
20
5
10
_d
110
1,400
800
280
60
20
5
20
.
-
70
350
220
50
20
5
50

-
-
1
40
40
10
4
100

-
-
-
-
10
10
4
200

-
-
_
_
_
3
3

                 Calculated using the  total  fugitive  hydro-
                 carbon  emission rate  of 1.7 g/s.

                 Downwind distance along the "plume"
                 centerline.

                Horizontal distance  from the "plume"
                 centerline.

                T)ash indicates  calculated concentration was
                 less than 1 (jg/m3.
                                      331

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                               Acknowledgements

This research was funded by the U.S. Environmental Protection Agency (EPA)
under Contract No. 68-03-2550.  The contents of this publication do not neces-
sarily reflect the views or policies of the U.S. Environmental Protection
Agency, nor does mention of trade names, commercial products, or organizations
imply endorsement by the U.S. Government.  Both MRC and EPA would like to
acknowledge the contributions of Hilding Spradlin and Steve Mankowski, Geo-
kinetics1 environmental engineers, whose assistance was invaluable during
preparation for and implementation of this sampling and analysis program.  The
role of David Farrier and Trudy Phillips of the Department of Energy's Laramie
Energy Technology Center (LETC) in allowing MRC to conduct field sampling at
the Kamp Kerogen site is also greatly appreciated.
                                      332

-------
                                  References

1.  Baughman, G. L.  Synthetic Fuels Data Handbook,  Second Edition.   Cameron
    Engineers, Inc., Denver,  Colorado,  1978.  438pp.

2.  Lekas, M. A.  Progress Report on the Geokinetics Horizontal In-Situ
    Retorting Process.  In:  Twelfth Oil Shale Symposium Proceedings,  Colorado
    School of Mines, Golden,  Colorado,  August 1979.   pp. 228-236.

3.  S. G. Mankowski, Geokinetics, Inc., Kamp Kerogen,  Utah, private
    communication, 1979.

4.  Zimmerman, P.  Procedures for Conducting Hydrocarbon Emission Inventories
    of Biogenic Sources and Some Results of Recent Investigations (paper pre-
    sented at the EPA Emission Inventory/Factor Workshop, Raleigh,  North
    Carolina, September 1977).  28 pp.

5.  Tierney, D. R., Z. S. Khan, and T.  W. Hughes.  Measurement of Fugitive
    Hydrocarbon Emissions from Petrochemical Plants (paper presented at the
    Third Symposium on Fugitive Emissions-.  Measurement and Control, San
    Francisco, California, October 23-25, 1978).

6.  Rinaldi, G. M., J. L. Delaney, and W. H. Hedley.  Environmental Characteri-
    zation of Geokinetics1 In-Situ Oil Shale Retorting Technology (draft report)
    U. S. Environmental Protection Agency, Cincinnati, Ohio, February 1980.
    239 pp.

7.  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.
                                      333

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                  A WIND TUNNEL STUDY OF FUGITIVE DUST FROM

                            TACONITE STORAGE PILES

                           Dr.  Robert B.  Jacko P.E.
                     Associate  Professor  of Environmental
                       Engineering and Health Sciences
                         School of Civil  Engineering
                           George M.  Palmer,  Ae.E.
                     Associate  Professor  of Aeronautical
                       Engineering and  Director  of  the
                        Aerospace Sciences  Laboratory
                   School  of  Aeronautical and Astronautical
                                 Engineering

                             Purdue  University
                           West  Lafayette,  Indiana


                                 ACKNOWLEDGMENT

     Sponsorship of this project was  provided by Mr.  Richard A.  Young of Young
Environmental Services, Glenview, Illinois  for which  we express  our appreci-
ation.

                                   ABSTRACT

     A comparative wind tunnel study of  the  fugitive emissions from a taconite
pellet test surface conducted at Purdue  University indicates that one of the
three commercially available dust suppressing agents tested at a dilution
ratio of 1 to 1000 was 33% more  effective than the least effective agent.
Water only was also found to be  as effective as the dust suppressing agents.
However, water and dust suppressing agents resulted in 3 times higher parti-
culate emissions than that of a  dry pile.  Both dry and wet transient testa
elucidated the nature of the particulate release.  For the wetted pellets,
subsurface drying appears to "mobilize"  interstitial and surface pellet mater-
ial which resulted in a higher release rate of particulate matter in time as
compared to a dry pellet.
                                      334

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                                 INTRODUCTION
     This report summarizes the results of a Purdue University study which in-
vestigated the effectiveness of various binding agents to control fugitive
dust emissions from taconite surfaces.  The three agents tested were composed
of hi-molecular weight polymers and synthetic resins.  They were all diluted
1:1000 with Indiana tap water.  At the outset, it should be understood that
this study is not a modeling study of a full size taconite storage pile.
Rather, this study is a purely comparative study with the objective of deter-
mining which of three chemical dust suppressing agents and also water do the
best job of reducing fugitive particulate emissions from taconite pellet sur-
faces.  The study is in reality a comparative parametric study utilizing a
large wind tunnel and other closely controlled procedures.  All taconite pre-
paration procedures and wind tunnel velocity were closely controlled in order
to discern the downwind particulate concentrations subsequent to application of
the various chemical dust suppressants.
                           WIND TUNNEL DESCRIPTION

     The subsonic wind tunnel at the Purdue University, Aerospace Sciences Lab-
oratory is shown in schematic detail in Figure 1.  The tunnel is a conventional
one with a 10-1/2 to 1 contraction ratio and is powered with a 400 H. P.
electric motor.  Speed control is obtained by means of a rheostat-controlled
electric clutch permitting a tunnel speed range from 10 mph to 300 mph in the
high-speed, closed test section.

     The present test program was conducted in the large open-throat test
section at the end of the 1st diffuser by means of a specifically designed and
constructed assembly described in Figures' 2 and 3 and shown photographically in
Figure 4.  This provided a flow at a nominal 1/2 of the high-speed section so
speeds could be varied and controlled from approximately 5 mph to 150 mph as
needed.

     The tests were conducted at a fixed velocity profile in the open-throat
section.  The speed was monitored by means of a pitot-static tube mounted up-
stream of the test surface, see Figures 2, 3 and 4.

     Figure 5 contains the vertical profiles of mean wind velocity and turbu-
lence intensity.  Note that over the pile height the wind velocity varied from
40 mph at the top to 20 mph near the base.  Turbulence intensity varied from
2% at the top of the pile to 5.5% near the base.  These levels of velocity and
turbulence intensities are typical of those expected in relatively flat terrain
such as would be expected from off-shore breezes which do exist near the full
scale taconite piles.
                                       335

-------
                                                                                 r
rT\
OJ
U-
c-
         FIGURE 1. LAYOUT AND  ELEVATION OF THE AEROSPACE SCIENCES LABORATORY SUBSONIC  WIND  TUNNEL  TOP  VIEW.

-------
          (AIR  SAMPLING
          NOZZLE  INLET
          DISTANCE  FROM
          PILE CENTERLINE)
                              fM
                                      AIR  FLOW
          PITOT-STATIC TUBE
ROUGHNESS ELEMENTS)
                               -26.5
                                                  (WIND TUNNEL FLOOR)
                       Figure  2.   Schematic Cross Section of Test Assembly.

-------
Oo
                        fcO
                        CO
                        LU
         -»-  AIR  SAMPLING NOZZLES

         0  PITOT-STATIC TUBE
                                      TEST
                                     SAMPLE -
                                      TRAY
                                                 AIR FLOW
            Figure 3.  Schematic Plan View of  Test  Assembly in Wind Tunnel.

-------
                                     (a)
                                     (b)



v'eure 4.  (a) Looking Upwind at Taconite Test Surface from Rear Sampling

* °            »T   1
               Nozzle


           (b) Side View of Taconite Test Surface with Flow Left to Right
                                      339

-------
             2.0
         o
         tH
         01
         
-------
                                TEST ASSEMBLY



     In order to facilitate testing for taconite fugitive dust,  an assembly  for
into the wind tunnel was designed and constructed.   Figures  2 and 3 are
schematics of the assembly installed in the large,  low-speed, open test  section
of the wind tunnel.

     The assembly was constructed of plywood, masonite,  and  construction lum-
ber. The 30° rise, see Figure 2, was constructed from untempered masonite
fastened to 5 plywood ribs.  This provided a stiff (non pulsing) surface with
a smoothly curved transition to the horizontal surface.   The horizontal  sur-
faces were constructed with sufficient strength and stiffness to permit  2 men
walking on them.

     The two dashed lines label plus and minus 26.5° in Figure 2 show the
hinged panels in the two positions for flat-tray attitudes of plus and minus
26.5°.  The back panel lays along the tunnel floor for the minus 26.5° po-
sition.

     Both Figures 2 and 3 show the assembly to scale in the horizontal po-
sition with roughness elements, instruments, and test pile location.

     Figure 4a is a top view looking upstream from the last air sampling noz-
zle.  Figure 4b is a side view of the conical test surface.  Flow is left to
right.


                               TEST PROCEDURES

Taconite Test Surface

     The basic approach in this study was to present a taconite test surface to
a constant velocity air stream while measuring upstream and  downstream partic-
ulate concentrations.  Initially it was proposed that the test  surface be com-
posed of a planar array of taconite pellets that could be presented at three
angles to the tunnel wind  flow.  The planar surface when presented at a  +26.5°
angle to the wind would represent a section of the upwind face  of a storage
pile.  When presented at a -26.5° angle to the wind the planar  surface would
represent the downwind face of  the pile.  At Cf angle the surface would  repre-
sent top and edges of the  storage pile.  Preliminary wind tunnel  tests  indicat-
ed that the angle of incidence  made little difference in the downwind particu-
late concentrations.  All  subsequent tests were therefore made  in a horizontal
mode  (0° angle  to the wind).  In addition, the absolute  downwind  particulate
concentration level was lower than desired for minimization  of  errors in the
gravimetric analysis.  Therefore the test  surface was changed from planar to
conical.

     The test surface was  made  from taconite pellets supplied from the  Michigan
Upper  Peninsula.  A  size distribution was  determined for  the pellets  upon
arrival at Purdue.   It was found that virtually no sizes  less than 1/4" were

                                      341

-------
present in the received pellets.  From previous taconite pellet size distribu-
tions it was known that copious fine dust does occur.  Therefore sufficient
taconite was pulverized in the soils laboratory at Purdue so that 2.5% by
weight less than 149 micron dust could be added to the received pellets.  A
two step procedure was utilized to form the fine dust.  The pellets were first
placed in a ball mill for approximately one hour, then through a pulverizer.
The ball mill was a "Los Angeles Type Abrasion Machine" manufactured by F. M.
Welsh Engineering Service of Greenville, Ohio and the type UA pulverizer was
manufactured by F. W. Braun Co., of Los Angeles, California.  Table 1 below
shows the resulting size distribution.

                  Table 1  Taconite Pellet Size Distribution

        Particle Size (S)                    % by Weight

        3/4" < s                              0.670 (as received)
        1/2" < S < 3/4"                      34.440   "     "
        3/8" < S < 1/2"                      61.400   "     "
        1/4" < S < 3/8"                       0.960   "     "

        (Added to the pellets in the laboratory)

        590y < S < 1/4"                       0.008
        296y < S < 590y                       0.024
        I49y < S < 296y                       0.493
         75y < S < I49y                       0.261
               S <  75y                       1.750

Test Surface Preparation Procedure

     The size distribution in Table 1 was followed in the making of all conical
test surfaces.  Following is the exact procedure utilized:

     1)  Place 2' x 2' x 2" deep wood test tray on 800 Ib. capacity Toledo®
         scale (31-1821-FD).  Adjust scale to zero weight.
     2)  Use Fairbanks-Morse beam balance scale (0-250 Ibs., Model 505) to
         weigh individual size fractions based on 100 Ibs. and pour onto test
         tray.  After weighing incremental fractions of 100 Ib. on smaller beam
         scale, check larger Toledo scale weight to ensure a sample weight of
         100 Ibs. has been achieved.  However, do not yet disperse less than
         149 micron dust on tray.
     3)  The pellets were then evenly spread over a specially built wooden
         trough 18" wide x 10* long x 1.75" deep.  The horizontal trough was
         supported 11-1/2" above the floor.  The purpose of the trough was tb~~
         present each pellet for evenly distributing the less than 149 micron
         dust as well as for spraying of suppressing agent.
     4)  Sieve the less than 149 micron size fraction of particles evenly over
         the pellets in the trough.
     5)  Using a Binks^Model 370 external mix spray gun at an inlet delivery
         pressure of 40 psig, evenly spray the pellets in the trough with 500
         ml of the selected dust suppressing agent.
     6)  Using a square wooden stick 1" x 1" in cross-section and 12" long,
         a furrow was ploughed through the pellets along the trough centerline
         returning back along the trough between the outer wall and trough

                                      342

-------
         centerline on each side.
     7)  The pellets are once again spread  evenly  over  the  trough.   This  pro-
         cedure exposes dry sides  of pellets  for more thorough wetting.
     8)  Proceed to spray another  500 ml of dust suppressing  agent  on  the now
         turned over pellets.
     9)  Using a 500 ml, polyethylene scalable bottle collect a  sample of
         pellets for moisture determination.
    10)  Using 8" wide x 10" long  metal sheets (0.040"  thick) scoop the pellets
         and carefully pour them into the center of the test  tray.   In this
         way, the pellets, evenly  dispersed with less than  149 micron  particles
         and wetted seek their 26.5° angle  of repose in the tray forming  a
         conical test surface.
    11)  Any fine particulate remaining in  the trough is brushed into  a sieve
         and evenly spread over the conical test surface.
    12)  The conical taconite pellet test surface  was then  positioned  in  the
         wind tunnel.  The elapsed time between wetting and test startup  was
         kept consistently at 10 minutes (conical  piling to test startup  was
         only 2 min.).


Particulate Sampling Procedures

     In order to quantify the differences between  the three chemical dust
suppressing agents, A, B, C and water as well as  dry test surfaces of taconite,
isokinetic particulate samples were taken.   During each test, except the trans-
ient tests, four simultaneous isokinetic samples were extracted using stainless
steel 1/4" inside diameter nozzles leading to 47 mm diameter filter holders.
Gelman type AE glass fiber filters were used for  all tests.  All filters were
handled and analyzed using standard gravimetric laboratory procedures.

     One sampling nozzle was  located upstream of  the conical taconite test sur-
face centerline, refer to Figure 2 and 3.  The upstream sample  served as a
"blank" to correct the downstream samples for particulate concentration.   All
samples were withdrawn isokinetically at 1.2 ft.  3/min.  Adjacent  to the up-
stream sampling nozzle a  standard pitot-static tube was  located for measuring
tunnel speed and maintaining  isokinetic conditions.  The pitot  tube as well as
all sampling nozzles were offset (staggered) from the tunnel and conical  test
surface centerline so none was in the direct downstream wake flow  of  the near-
est upstream nozzle.


Air Flow Instrumentation

     The air samples were taken using  3 EPA Method  5 type control  cases  (Joy
Manufacturing  Co.) and one diaphram  pump and a rotameter.  The  method 5  type
control cases  are  equipped with a leak-free vacuum  pump, dry gas meter,  flow
control valves and an orifice rate meter.  The orifice meter was used  to set
up the isokinetic  sampling rate.  Each  control case was  previously calibrated
against wet  test meters  in the School  of Civil Engineering's Air Pollution
Measurements Laboratory.  The fourth pump and rotameter were also  calibrated
prior  to use.  All air volumes measured were corrected  to  standard conditions.
                                      343

-------
 Specific  Test  Procedures  -  60 min.  Samples

     With the  wind  tunnel having been  previously  "warmed up," the drive clutch
 was  disengaged and  the  tunnel was brought to  its  lowest possible speed of about
 2 mph.  The conical  taconite test surface was placed in position and the sam-
 pling  system started.   The  tunnel clutch was  then engaged and air speed was
 brought to 40  mph at pitot  tube height  in approximately one minute.  Sampling
 continued for  60 minutes  and therefore  all data except the transient test data
 are  one hour time average samples.  The filters were stored in glass petri
 dishes and the nozzles  were quantitatively backwashed with acetone.  The total
 particulate sample weight was therefore composed of the filter weight gain
 portion and the nozzle  backwash portion.


 Transient Test Procedures

     Everything for  the transient tests were  identical to the one hour time
 average samples except  the  filter heads were  exchanged at the second downwind
 position  with  time.  This involved  recording volumes, recovering filters and
 backwashing nozzles  in  a  very closely coordinated effort.  In this way, the
 particulate concentration variation with time was determined.
                            RESULTS AND DISCUSSION

Steady State Measurements

     The results from the one hour sampling time test series are presented in
Tables 2, 3 and 4.  Each table presents the concentrations in milligrams per
cubic meter for each of the three downwind positions.  The overall space and
test-wise average is shown in a box to the lower right of each table.  Note
that copious replicate data is contained in Tables 2, 3 and 4.  Nine parti-
culate concentration values went into the dry taconite surface test average
twenty-seven into the dust suppressent tests and 13 for the water tests.

     In addition, the various tests were conducted such that systematic errors
would be minimized.  For example, the test runs were mixed in time so that
systematic errors were minimized.  The test run numbers increase with calen-
dar time.  Test run one corresponds to Sunday, March  2, and run 18 to Friday
March 28, 1980.

     In viewing the data, it becomes very apparent that the overall average
downwind particulate concentration is lowest for the dry conical test surface
The dry surface resulted in a 2.63 mg/m3 downwind average concentration while
the test surfaces treated with suppressing agents averaged 7.80 mg/m3.   The
dust suppressing agents were all mixed at a dilution ratio with fresh tap water
of 1 in 1000.  The amount of agent added to the pile resulted in a 1.1% pellet
moisture content by weight.

     There appears to be a trend regarding the most effective suppressing
agent, however.  Note in Table 3 that the use of agent "C" resulted in the
lowest downwind particulate concentration of 6.15 rag/nr.   Agent "B" was
8.12 mg/m3 and agent "A" 9.13 mg/m3.


                                      344

-------
TABLE 2  Downwind particulate concentration from a dry taconite test
         surface
                          (Wind Speed = 40 mph)

                       (1 hr. sampling time average)

Test
No.
1
4
5
AVG.

1.6
o
mg/m
0.78
4.86
3.25
2.96
L/D3
2-7
mg/m
3.48
3.50
2.74
3.24

4.8
mg/m3 AVG .
1.52 1.93
2.30 3.55
1.28 2.42
1.7 2.63 b
a.  L is downwind distance from pile centerline  to sampling nozzle  inlet.

    D is pile diameter at the elevation of nozzle.

    L/D  is not a scaling parameter  to be  applied to  a  full  scale  situation,
    it is being used  for convenience.

b.  All values corrected for background particulate  which in  most cases  was
    negligible.
                                    345

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TABLE 3  Downwind particulate concentration from a taconite test surface
         composed of pellets treated with dust suppressing agents


                          (Wind Speed = 40 mph)

                       (1 hr. sampling time average)

           Dust
Test Suppressing
No. Agentb
6
15
16
3
7
14
8
17
18
AVG.
A
A
A
B
B
B
C
C
C
1.6
mg/m
9.35
11.55
6.45
8.60
8.02
7.12
7.36
5.28
4.19
7.55
L/D3
2-7
mg/m-*
12.40
11.25
7.08
9.57
8.82
11.35
9.21
6.86
4.62
9.02
4>83
mg/m
7.00
10.35
6.72
5.33
6.90
7.44
6.62
6.03
5.20
6.84
AVG.
9.59
11.05
6.75
7.80
7.91
8.64
7.73
6.06
4.67
Agent
Average

9.13


8.12


6.15

17.80 1
 a.   L is downwind distance from pile  centerline  to  sampling  nozzle  inlet.

     D is pile  diameter  at  the  elevation of  nozzle.

     L/D is  not a  scaling parameter  to be applied to a  full scale  situation
     it is being used  for convenience.

 b.   Amount  applied such that resultant pellet  moisture content  approxi-
     mately  1%  by  weight.   All  suppressing agents diluted  in  fresh tap  water
     to 1 in 1000.

 c.   All values corrected for background particulate which in most cases was
     negligible.
                                   346

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TABLE 4   Downwind particulate concentration from a taconite test surface
          using Indiana tap water0 as a dust suppressant.


                         (Wind Speed = 40 mph)

                      (1 hr. sampling time average)

                                   L/Da
Test
No.
2
9
10
11
13
AVG.
mg/m
9.13
8.53
4.17
5.63
8.54
7.20
27 4.8
*•»'« *}
mg/m mg/m
11.2 9.1
8.90 8.57
8.83
9.66
10.06 7.8
9.73 8.49
AVG.
9.81
8.67
6.50
7.65
8.80
8.47
 a.  L is downwind distance from pile centerline to sampling nozzle  inlet.

     D is pile diameter at the elevation of nozzle.

     L/D is not a scaling parameter  to be applied  to a  full scale  situation,
     it is being used  for convenience.

 b.  Amount applied such that resultant pellet moisture content  approxi-
     mately 1% by weight.

 c.  All values corrected for background particulate which in most cases
     was negligible.
                                    347

-------
     From Table 4, the use of water only as a dust suppressing agent resulted
 in a downwind particulate concentration of 8.47 mg/m  .  The amount of water
 added and the procedure used to spread it over the pellets was identical to
 that of the suppressing agents.  For all water only tests, the average pellet
 moisture content was 1.07%.

     There appears to be a significant difference between a dry taconite sur-
 face and a surface which has been treated with suppressing agent and water or
 water only.  The dry taconite surface fugitive dust concentration is signifi-
 cantly lower than the suppressing agent surface or the water only treated sur-
 face.

     Further, it appears that the suppressing agent and water mixture (Table
 3) are no better in reducing fugitive dust than a surface treated with water
 only.  The suppressing agent surface resulted in a downwind concentration
 average of 7.80 mg/m  while the water only treatment was 8.47 mg/m .

     A graphical display of the same data presented in Tables 2, 3 and 4 is in
 Figures 6, 7 and 8.  From these plots the differences between the suppressing
 agent and water only treated surfaces to the dry surface are clearly evident.
 The variation with distance in downwind concentration is due to the nature of
 the aerodynamic flow around a cone.  The greater variability in concentration
 at the 1st downwind measurement station (L/D - 1.6) as compared to the 2nd
 (L/D = 2.7) and 3rd (L/D = 4.8) is also due to the nature of the aerodynamic
 flow over and around a cone.   The 1st downwind sampling nozzle is located in
 the downwind aerodynamic cavity of the cone and the resulting turbulence and
 vortex shedding causes the concentration variation to be greater than that at
 the two further downwind stations.

     Note also that the 2nd downwind station has slightly higher concentrations
 than either the 1st or 3rd measuring station.  This effect is due also to the
 nature of the flow over and around a conical form and cannot necessarily be
 extrapolated to a full scale taconite piles since they are in essence elongated
 cones.

     The foregoing results were not expected from these tests.  Intuitively
 it was expected that the dry pile would yield the highest downwind particulate
 concentrations with the water only and suppressing agent mixed with water
 following in decreasing concentration.  However, the repeated concentration
values for each test series are supportive of the statements made in reference
 to each test.   Further testing was therefore undertaken to elucidate the nature
of the particulate release from the taconite surface.  The further tests con-
ducted were transient as compared to steady state and support a particulate
release hypothesis that is covered in the next section.


Transient Measurements

     A series of three transient tests were performed to determine the time
dependency of the downwind particulate concentrations from the taconite test
 surface.   From these tests three plausible theories are suggested to explain
 the higher particulate release rates for wetted and then dried taconite
pellets.
                                      348

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      Figure 6.  Downwind participate concentration  from  a dry taconite test  sur-
                 face.
 O>
 6
oc
»-

LU


O
ee.
a.
     12
     10
0    8
HH    "
TEST RUNS

  01

  03 5

  A4

  019  (DRY TRANSIENT  TEST-TIME
        WEIGHTED  AVG)
                              A
                                                    (WIND TUNNEL SPEED = 40 mph)

                                                    (1  HR.  SAMPLING  TIME AVERAGE)
                                                                            A
                                                                           4.8 5.0
 L/D, RATIO OF  DOWNWIND  DISTANCE TO CONICAL TEST SURFACE DIAMETE AT NOZZLE ELEVATION

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             Figure 7.  Downwind particulate concentration  from  a  taconite   test   surface
                        composed of pellets treated with  dust  suppressing  agents.
OJ
Ln
O
    O>
    e
     V

    O
O

O
         12
         10
         8
TEST RUNS:

    0 3
    0 7
    A6
    O8
    V14
                  017
                  a is
                                         (WIND TUNNEL SPEED  =  40 mph)

                                         (1 HR.  SAMPLING  TIME  AVERAGE)
                                                  I
                        1.0
                  1.6   2.0
                                             2.7 3.0
4.0
4.8 5.0
       L/D, RATIO OF DOWNWIND  DISTANCE  TO  CONICAL TEST SURFACE DIAMETER AT NOZZLE ELEVATION

-------
            Figure  8.   Downwind particulate concentration from  a  taconite   test   surface
                       using Indiana tap water as a dust suppressant.
to
Ul
   O»
   6

    s

   O
   UJ
   C_)

   O
   O

   UJ
        12
       10
8
        0
                       1.0
J	L
                                                 O
                                             (WIND TUNNEL SPEED =  40  mph)

                                             (1 HR. SAMPLING TIME  AVERAGE)
                                                     _L
                       1.6   2.0
               2.7 3.0
4.0
                                                                       O
                                                                      J	i
4.8 5.0
     L/D, RATIO OF DOWNWIND  DISTANCE TO CONICAL TEST SURFACE DIAMETER  AT  NOZZLE  ELEVATION

-------
     Table 5 contains the downwind particulate concentration data and the
corresponding time into the one hour test.  The test was conducted by placing
the wetted taconite test surface  (1.1% moisture by weight) into the wind
tunnel, initiating particulate sampling,  then bringing the tunnel up to 40
mph.  The sampling nozzles were quickly interchanged at downwind sampling
sampling position no. 2 as time into the  test increased.  The tests were ter-
minated after 60 minutes.  A plot of the  data is seen in Figure 9.  A sharp
increase in particulate concentration is  seen within the first 1.5 minutes then
a rapid decrease at 4.5 minutes beyond which the concentration increases rapid-
ly once again at 5 minutes.  The peak value of the second increase is much low-
er than the first.  Beyond 5 minutes, the particulate concentration exponent-
ially decays until at 60 minutes into the test, the concentration appears
steady state and approaching that value seen earlier for the dry pile concen-
tration of 2.63
     The rapid increase seen within the first 1.5 minutes is due to relatively
large material as examination of the filter pads revealed.  This large parti-
culate is probably loosely held to the taconite pellet surface and is mechan-
ically removed by the action of the wind.  Next, the surface of the pellet be-
gins to dry as the surface moisture is evaporated.  Since the initial large
particles are quickly removed by wind action (within first 1.5 minutes at 40
mph), the concentration sharply decreases between 1.5 minutes and 4.5 minutes.
By this time (4.5) subsurface drying is now occuring with the water vapor
proceeding through the interstices of the pellet material.  This subsurface
evaporation appears to trigger a rapid increase in particulate emissions be-
tween 4.5 minutes and 8.5 minutes into the test which may be due to the water
vapor entraining fine particulate matter.  Beyond this time the particulate
concentrations exponentially decay out to 60 minutes.  The decay approaches the
steady state dry pile test previously shown in Table 2 of 2.63 mg/m .

     Subsequent to the initial release of the large particulate at 1.5 minutes
three theories are suggested for the particulate emission behavior.

     1)  As the subsurface drying occurs, water vapor off-gases through the
         interstitial pellet material carrying with it fine particulate matter.
     2)  The absorption of the water chemically reacts with some unknown con-
         stituent such as a calcium rich material which after firing could be
         CaO (hydrated lime) which is water soluble.  In essence the water
         weakens the bond between pelletized particles causing higher parti-
         culate release rates.
     3)  The drying of the pellet surface causes "micro-spalling" of the
         pelletized material thus releasing more particulate.

     The decay portion of the curve in Figure 9 is explained by a finite amount
of material that is being removed from the pellet.  In the limit, therefore,
the curve should decay to the dry taconite surface downwind concentration.
Recall that the 60 minute time average concentration shown in Table 2 for dry
taconite was 2.63 mg/ra .   The decay curve of Figure 9 is obviously approaching
this value in the limit.

     Note also in Figure 9 that a curve is shown for a dry taconite surface.
This test was run to confirm that the dry taconite surface is lower in fugitive
emission at 40 mph than one which has been wetted and allowed to dry.  Table 6
contains the dry transient data.   As expected the initial release of loose sur-

                                      352

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TABLE 5   Particulate concentration variation with time for
          taconite test surface composed of pellets wetted
          with Indiana tap water3.
Test Numbers

10, 11, 12
                          (Wind Speed = 40 mph)
Particulate
Concentration
at L/D = 2.4
    o
mg/nr
Time into test
(midpoint of
sampling time
interval)

   minutes
32.45
46.40
37.00
8.97
2.94
25.50
19.90
16.50
12.10
9.71
14.30
8.83
8.87
5.03
5.00
5.61
1.86
3.84
1.0
1.5
2.5
3.5
4.5
5.0
5.0
8.5
12.0
16.0
15.5
25.0
27.0
38.0
40.5
49.0
56.0
60.0
  a.   Amount of water added such that resultant pellet moisture content
      approximately 1% by weight.

-------
TABLE 6      Particulate concentration variation with time
             for a dry taconite test surface3.
                         (Wind Speed = 40 mph)
                            Particulate
                            Concentration
                            at L/D = 2.4
Time into test
(midpoint of
sampling time
interval)
Test Number mg/nr
19 56.73
25.31
25.02
4.74
0.83
0,24
3.15
0.71
a. No water or agent added to pellets
minutes
1.0
3.0
5.0
7.0
12.0
23.0
37.5
52.5

                                  354

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Ui
                  ^    50
                   p   40
                  P,   30
                  g   20
                  at
                  Q.
                  O
                       10
                                       RELEASE OF LARGE LOOSELY BOUND SURFACE PARTICLES
                                         INITIAL  SURFACE  DRYING
                                                                     NOTE: MOISTURE CONTENT OF PELLETS AT START OF TEST:
                                                                           1X BY WEIGHT
                                            RELEASE OF "SPALLED" SURFACE MATERIAL
                                                                    TRANSIENT DRY PELLET TEST
                                                                              PARTICLE EMISSION DECAY  AS  SPALLED MATERIAL
                                                                              IS REMOVED FROM PELLET SURFACE
                                                                                                              -©
                                       10
20
    30

TIME, MINUTES
40
50
60
                                Figure 9.  Transient  particulate emission characteristic from wetted  tacon-
                                           ite  test  surface  at  40 mph and a dry taconite test surface.

-------
face particulate results in the high 56.73 mg/m^ concentration after only 1.0
minute.  After 7 minutes, however, most of this fine particulate is gone and
the dust concentration drops to 4.74 rag/nr.   Beyond this point, the concen-
tration is very low compared to the wetted and drying surface.
                                 CONCLUSIONS

     1)  A dry taconite surface when exposed to a vertical wind profile from
         20 to 40 mph results in a substantially lower downwind particulate
         concentration than one which has been wetted and then allowed to dry.

     2)  Of the three commercially available dust suppressing agents tested at
         a dilution ratio of 1 to 1000, one agent appeared to be more effect-
         ive than the others.  The more effective agent reduced the downwind
         particulate concentration by 33% over the least effective agent.

     3)  Using three commercially available dust suppressing agents diluted 1
         in 1000 with Indiana tap water appear to be no better than using
         water only to suppress dust from a taconite pellet surface.  Water
         resulted in a dust concentration of 8.47 mg/m-* and suppressing agent
         7.8 mg/m3.

     4)  The taconite surface when wetted either with water only or a suppres-
         sing agent mixed with water at a dilution ratio of 1 in 1000 causes
         about 3 times higher particulate concentrations than a dry pile with
         no agent whatever applied.

     5)  The transient release of particles from a wetted surface appears to
         be strongly related to the use of water.   The water somehow causes
         the surface of the pellet to become much more susceptible to the
         release of particulate matter.

     6)  When water  is used to control fugitive dust from a taconite surface,
         the surface must  not be allowed to dry but be continuously wetted.
                                     356

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                       COMPUTING  DESIGN CHARACTERISTICS

                       FOR COAL PILE DRAINAGE TREATMENT
           Presented at the Fourth Symposium on Fugitive Emissions;
                           Measurement and Control
                               May 28-30, 1980
                   Monteleone Hotel,  New Orleans,  Louisiana

                   Pamela B.  Katzf P.E.,  Principal Engineer
                        John A.  Ripp,  Project Engineer
                        TRC Environmental Consultants
                                   ABSTRACT

    Under Section 304(e)  of  the Clean Water Act, the U.S. EPA  is  developing
a  program of Best  Management  Practices  (BMP's)  for  control  of  toxic  and
ha2ardous  discharges  from  ancillary  industrial  sources.    These   sources
include plant-site runoff, spills and  leakage, sludge or  waste  disposal,  and
raw-material drainage.

    For  many electric  utilities,  BMP means evaluating  coal  storage  piles
with  regard  to the  quantity and quality  of storm  related  and dry  weather
drainage.  Coal  pile drainage  is usually  characterized as acidic with con-
centrations of trace metals, iron, sulfur,  and solids.

    TRC  is  developing  a  mathematical model  to  simulate coal  pile  drainage
for the  design  of appropriate  treatment systems.   The  model will allow for
the consideration of various antecedent meteorological conditions including
rain  and snow  precipitation,  freeze-thaw phenomena,   and  air  temperature.
Other hydrologic phenomena the  model will evaluate are:

    o  pile  runoff
    o  snowmelt
    o  percolation through the  pile
    o  infiltration  into  groundwater
    o  evaporation

    The  model  will  also  simulate  coal  pile  runoff   quality.   Components
included are framboidal  pyrite oxidation, acid  production,  and  the  subse-
quent release of  trace  metals.

    TRC  will discuss how its model is one  available method  to characterize
coal  pile runoff under varying meteorological conditions.  TRC is currently
developing  an extensive  field  program at  a  number  of  utilities to calibrate
and verify  the model.
                                       357

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                               1.0   INTRODUCTION

    Current practice  to  compute design characteristics for coal pile  runoff
treatment  may  be  overly  conservative and  unnecessarily costly.   Accepted
practice  dictates  that storage/treatment  be  designed  to  accomodate all  of
the  runoff  from  a  10   year-24-hour  storm.   EPA-sponsored^  studies  com-
pleted by  TRC in 1976 at utility power  plants  in Pennsylvania suggest  that
while  initial  stormwater  runoff contains relatively high  levels of  contami-
nants,  the pollutant  concentrations  decrease   rapidly  as  the  storm  pro-
gresses.   Why,  then not   store  and  treat the initial "dirty" runoff and  by-
pass the subsequent "clean" water if it meets NPDES limits?

    This  concept has  captured  the  interest  of  the  Utility  Industry.   The
industry through UWAG, EEI,  and EPRI  is  presently participating  in a  joint
EPA-Utility Industry-TRC  project  to develop mathematical  modeling and  moni-
toring techniques  that can  be  used to  characterize  coal pile runoff  on  a
dynamic basis  for  a  storm event.   This project has  started  where  the  pre-
vious EPA-TRC efforts left off.

    This paper  will discuss  the  conclusion of  previous  coal pile  drainage
monitoring efforts,  and   the  objectives  of the  current EPA-utility program
including  the development of  a mathematical model  for  coal pile drainage  and
the related field program for calibration and  verification of  the model.
  Brookman,  Binder, Wade, "Sampling and Modeling of Non-point Sources at
   a  Coal-fired  Utility", EPA - 600/2-77 - 1979, September 1977.
                                      358

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                    2.0  PREVIOUS COAL PILE RUNOFF PROGRAMS

    In 1976 coal pile runoff was  investigated  by TRC for two  steam electric
generating stations  in  Pennsylvania-Warren Station of  Pennsylvania Electric
Company and Portland station of Metropolitan Edison Company.1

    At each site, a  network of sampling stations was established  to collect
coal  pile  runoff during the duration  of  several storms and  the  intervening
dry periods.   Samples  collected were analyzed  for  pH,  sulfate,  alkalinity,
total and dissolved solids, acidity, total iron, aluminum,  and manganese.

    Several interesting observations were made during the  field program.


    1)   The  seepage  from  the  base of the  coal  pile after the  storm event
         was orders of magnitude more concentrated  than the  wet weather  run-
         off stream.

    2)   At  the  beginning  of the  storm,  a "first  flush" with higher pollu-
         tant  concentrations could  be seen.   Through  the  rainfall  period
         these  values  generally  declined.   For  example,  acidity  levels  on
         the September  17,  1976 storm  at  Warren Station were initially 3200u
         g/1  and declined  throughout  the storm.   When the rain  ended  five
         hours later the acidity was 500 Pg/1.


    Tables  2-1 and  2-2  show analysis  results  from  the Warren site.  These
two phenomena can be seen  in the results.

    The  results  of  the 1976 field  program were used to calibrate  the SSWMM-
Receiv II  model  developed  by TRC  for predicting  the  quantity  and quality of
stormwater  runoff and  its  impact  on   receiving  waters.   The  model  results
compared  favorably  with  field measurements  but identified  several  limita-
tions  in the SSWMM-Receiv  II  model.   These limitations include  the  lack of
capability  to  simulate  storm  erosion from  material  storage piles  and  to
simulate  stormwater percolation  through  material  storage  piles.  With these
limitations  in mind, TRC outlined  a scope  of work to develop a model  to bet-
ter simulate coal pile drainage and a field  program to  verify  it.
   Brookman,  Binder,  Wade,  "Sampling  and Modeling  of  Non-point  Sources  at
     a Coal-fired  Utility",  EPA - 600/2-77  -  1979,  September  1977.
                                       359

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                                                                                   TABLE 2-1

                                                                     CHARACTERISTICS OF COAL PILE RUNOFF
                                                                        DURING SECOND STORM EVENT AT
                                                          WARREN STATION OF PENNSYLVANIA ELECTRIC CO., WARREN, PA.
                                                                              17 SEPTEMBER 1976
LO
O
O



1000
1015
1030
1045
1100
1115
1130
1200
1230
1300
1330


TIME
- 1015 - Rain Start
- 1030
- 1045
- 1100
- 1115
- 1130
- 1200
- 1230
- 1300
- 1330
- 1500 - Rain End
POLLUTANT

TSS
9800
4200
6400
11400
5000
1700
1400
1600
1700
1700
23000

TDS
4600
3300
2400
2400
2500
3700
3800
3100
3000
-
500

SO,,
2300
2300
1600
1800
2100
2100
2700
1700
1000
-
200
COAL PILE
FE
900
-
700
1400
700
500
-
300
200
-
-
RUNOFF
AL
101
-
9
7
8
-
-
-
-
-
-


MN ACIDITY
40 3200
2600
10 3100
10 2000
10 2200
2900
-
2 500
DISCHARGE
FLOW RATE
1pm (gpm)
22 (5.8)



20 (5.3)

20 (5.3)
17 (4.5)

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                                                                               TABLE 2-2

                                                          CHARACTERISTICS OF COAL PILE LEACHATE-DRY WEATHER
                                                     AT WARREN STATION OF PENNSYLVANIA ELECTRIC CO., UARREN, PA.
                                                                      AUGUST - SEPTEMBER, 1976
lo
Date
8/25/76
8/27/76
9/16/76
Hours Since
Last Rain
250
17
505
Pollutant Concentration, mg/1
TSS
200
18,700
12
IDS
40.000
82,600
21,700
SO,,
57,000
45,000
25,000
Fe
23,500
14,000
9.700
Al
1,800
1,400
1.100
Mil
100
70
70
Acidity
18,000
27,000
37,600
pH
2.4
2.1
1.5
Discharge Flow Rate
Ipin (gpm)
1.5 (.39)
1.5 (.39)
1.4 (.39)

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                     3.0  OBJECTIVES  OF THE  CURRENT PROGRAM

     As  a part  of the  program to develop  predictive measures  and methodo-
 logies   for  fugitive  emissions,  EPA's   Industrial  Environmental  Research
 Laboratory  (IERL-RTP)  has sponsored  a study based  on TRC's recommendations
 to  develop  a predictive model for coal pile drainage.  This project was also
 of  interest  to  utilities; hence,  additional funding and support was provided
 by  the  Edison Electric Institute  (EEI) with special emphasis  by its Utility
 Water Action Group (UWAG).  TRC  has  been working with  a  technical advisory
 group consisting of utilities, EPA  and  technical  organizations to ascertain
 the  utilities'   needs  in  predictive  methodologies  for  coal   pile  drainage
 treatment design.

    The EPA  - EEI  program has  several  components currently funded:


    1)   Research  and  evaluate existing models  in  related  fields and specify
         model modifications needed to simulate coal pile drainage.

    2)   Query  the coal  fired utilities  as  to  the data  available on  coal
         pile drainage.   Assemble results of utility  questionnaire  for  dis-
         tribution.

    3)   Develop  model,  evaluate  parameter sensitivity  and  model  short-
         comings.

    4)   Develop a field program design to calibrate and verify  the model.


    The  above phases were completed in May,  1980.

    In the upcoming  phases,  the  field program  will be conducted,  the model
fine-tuned  and modified, and  a user's manual will  be developed.
                                     362

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                     4.0  DEVELOPMENT OF A  COAL PILE MODEL

    Using  the  experience  of runoff modeling  in  the Pennsylvania  field  pro-
gram, and  with  input  from  the  Technical Advisory  Committee,  TRC developed an
outline of the physical/chemical phenomena  to  be contained  in a  coal  pile
drainage model.   These  are summarized  below.  The result  of  their inclusion
was  a  continuous simulation model  to  predict the dry  and wet  weather  flow
quantities and characteristics.


                         4.1   Quantitative Phenomena

     1)   meteorology  - hourly  input of rain, snow, and air temperature
     2)   surface  runoff
     3)   snowmelt
     4)   percolation  through  the coal  pile, interflow from  the sides of the
         pile


     A  schematic  diagram of the coal pile  hydrology for the model  is  shown in
figure  4-1.


                           4.2   Qualitative Phenomena

     1)   pyrite  oxidation,  acid production
     2)    freeze-thaw cycles accelerating oxidation
     3)   gully erosion
     4)    coal  pile  washoff of  pollutants
     5)    reactivity of  trace metals


     The methodology  by  which  the  phenomena are  addressed  in the model  is
described  in the following section.
                                       363

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                                                                        UPPER ZONE STORAGE = DEPRESSION STORAGE
                                                     DEPRESSION
                                                       STORAGE
                      EVAPORATION
                                       NFILTRATION
RUNOFF
STREAM
1
DIRECT RUNOFF
                                              LOWER ZONE
                                                STORAGE
                                                  I
        PILE MOISTURE
                                  WATER TABLE
                                                         GROUND WATER
                                                  RUNOFF
                                                  STREAM
                                                                 TO DEEP STORAGE
                          FIGURE 4-1:   SCHEMATIC OF HYDROLOGJC CYCLE COAL STORAGE PILE

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                            5.0  MODEL DESCRIPTION

                       5.1   Base Model and Modifications

    TRC  investigated  a number of  runoff models  to  use  as a  base  structure
for coal pile drainage.  These included  SWMM,  STORM,  ARM,  Stanford  Watershed
Model, and the Pyritic Systems model.

    The  Ohio  State University version  of  the  Stanford  Watershed  Model  was
selected  as  the  base model  because  it was  a  continuous  simulation  with
infiltration/percolation  features.   TRC utilized   the  1977  version,  made
available through the Extraction Technology Branch of the U.S.  EPA.

    The  OSU watershed  model simulates the hydrologic cycle of  a rural area.
Features are included  in the model  for  interception of rainfall by  vegeta-
tion,  transpiration,  infiltration  into  the soil,  percolation,  evaporation,
overland flow,  soil moisture, depression storage,  and  ground water  flow to
deep storage.

    OSU  also developed  a qualitative strip mine  and  refuse  pile model to be
used in  conjunction with the OSU version of the Stanford Watershed Model.

    Both OSU co-models  required  extensive revisions  to  contain  all the phy-
sical/chemical phenomena discussed  in Section  4.  TRC deleted  from the model
a  number of routines  not  applicable  to coal  pile  drainage,  such  as those
relating to vegetation.  In addition, a  number of the features were added to
the model.  These are listed below:


    1)   Addition of  gully  erosion to simulate the  transport  of solids from
         the sides of the pile.

    2)   Simulation  of  pyrite oxidation and acid production  with the subse-
         quent release  of  dissolved iron, sulfate,   and  trace  materials dur-
         ing rainfall events.

    3)   Consideration  of  the  acidity  of  rainfall and  the  alkalinity of
         coals.

    4)   Consideration  of  the  impact  of  freeze-thaw  cycles  on  the active
         coal surface area  and subsequent pyrite  oxidation.

    5)   Inclusion  of a  less  complex  snowmelt  routine.

    6)   Modification  of  the  meteorological input  to allow  the use of  stan-
         dard NOAA magnetic tapes  of historical meteorological data.


                       5.1.2  Coal  Pile  Hydrology Model

    TRC's  coal  pile hydrology model based on  the OSU version  of the  Stanford
Watershed Model  is  called TRCH20.
                                      365

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     TRCH20  considers rainfall infiltration,  gully  erosion,  runoff,  snow ac-
 cumulation  and  snowmelt  at  the  coal pile  surface.   In  addition,  moisture
 percolates  through the pile  to seep  from the side  of the pile, enter ground
 water  beneath the pile,  or to be  emitted  as seepage from  the base  of the
 pile.

     TRCH20  uses  a standard National Climatic Center magnetic data  tape of
 hourly  weather observations for  a  selected station as meteorological  input.
 The  data  concerning  the  coal pile itself is  input  to the model  by  a small
 card deck.
                      5.1.3  Coal Pile Qualitative Model

    TRC's version of the OSU strip mine  and  coal  refuse pile  model  is called
TRCCOAL.

    TRCCOAL operates in either  a  dry  day or  wet day mode,  depending on daily
rainfall.  On dry days,  framboidal  pyrite in the coal  is  oxidized  producing
acid,  dissolved sulfate,  and   iron.   The acid further reacts  to  dissolve
trace  materials  in  the coal.   The  number of  freeze-thaw  cycles during  the
preceding dry days  accelerate  the breakup of coal  and  the subsequent pyrite
oxidation.  Moisture is emitted from the  lower  zone of  the coal  pile  as  see-
page.

    During wet  weather, dissolved materials  are washed from  the surface  and
to the other  zones  of  the pile.  They are then washed out of the  coal  pile
to the runoff stream.  The model then returns to its dry/wet day  cycle.

    The TRCCOAL model uses a tape created by TRCH20 for hydrologic data  and
a small card deck describing the characteristics of  the coal pile.
                                      366

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                              6.0  MODEL OUTPUTS

                                 6.1  TRCH20

    The quantitative model,  TRCH20,  can be run without  the  qualitative  com-
ponent.  It prints a tabular output of  precipitation,  runoff flows,  and  pile
moisture data.   The  basic  data is presented as daily  flows  and loadings for
the year.  After data analysis the user  can choose  output  intervals  at hour-
ly or  less  intervals for a  selected  time interval.   Some of the more detail-
ed  data is  presented  as user selected  options.   The  output  of TRCH20  is
listed below:
    Basic Outputs

    1)   A  table of average daily rainfall in inches,

    2)   Summation  of synthesized  daily  runoff  rates,  in  cubic  feet  per
         second, for each month, followed by the annual total.

    3)   Synthesized monthly  and  annual  totals for  each  of  overland  runoff,
         interflow, baseflow, and total flow, in inches.

    4)   Monthly and  annual  totals  of  liquid precipitation,  in water equiva-
         lent  inches, developed from the meteorological input.

    5)   Monthly and  annual  totals  of  frozen precipitation,  in water equiva-
         lent  inches, developed from the meteorological input.

    6)   End of month  values,  in inches, of  pile,  surface,  and ground water
         moisture.

    7)   End of  month values for indexes  of  ground water slope and pile de-
         pression storage.

    8)   End of month values for snowpack  in water  equivalent  inches.

    9)   And annual balance, in inches, of unaccounted  for moisture.


    Optional Outputs

    1)   Echos all  input data.

    2)   For one  selected  storm per year, prints values, in  inches,  of  rain-
         fall  deposition,  moisture storage,  runoff origins  and runoff  out-
         flow  for each time  interval.

    3)   Prints  daily values of selected  variables to give a better  indica-
         tion  of  the program  interactions  in the  upper,   lower,  and  deep
         zones of  the  pile.
                                       367

-------
     4)   Echos recorded runoff flows,  in cubic  feet  per  second,  for  compari-
          son with simulated flows.

     5)   Records the  twenty highest clockhour  rainfall  events in the  water
          year.

     6)   Prints daily pile moisture storage,  in  inches.

     7)   Prints daily  values  of  the  snowpack,  snowmelt,  and  snowfall,   in
          water equivalent  inches.

     8)   Prints out  average daily  temperature  in °F.

     9)   Prints out  number of  freeze-thaw cycles in preceding dry days.

    10)   Prints out  simulated gully  erosion  of  solids to  the  base of  pile
          in-pounds per day.

    11)   Plots an arithmetic  hydrograph for  water  year  comparing recorded
          and  simulated flows.

    12)   Plots an arithmetic hydrograph and rainfall  hyetograph for selected
          data.

    13)   Prepares tape output  file  for  use as  input to TRCCOAL.


     Plots  of   the annual  runoff hydrograph are   prepared  by  the model.   An
example  output showing simulated  runoff flow  over the water year is present-
ed  in  Figure  6-1.   This  hydrograph can also  include recorded  runoff  flows
for  a  comparison with the modeled  values.  An optional  plot  of the rainfall
hyetograph  and runoff hydrograph  for a selected detailed storm  is  shown  in
Figure 6-2.


                                 6.2  TRCCOAL

    The  co-model  TRCCOAL  calculates the amount  of acid,  sulfates,  iron  and
trace  materials  in  the runoff stream and summarizes  it  on a  daily, monthly
and annual basis.  Below are listed the tables produced by TRCCOAL:


     1)   Daily  loadings of acid,  iron,  sulfate,  and  trace materials in the
         direct runoff, interflow, and seepage, in pounds.

    2)   A calendar  of  simulated daily  runoff  flow volume,  in cubic feet per
         second.
    As in the hydrologic model, printouts of  hourly  data  can be  chosen for a
selected time interval.  In  addition,  the model produced plots  of  pollutant
loadings.  An example plot  is shown in Figure 6-3.
                                      368

-------
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FIGURE 6-1
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                    0.00  10.00  20.00
                             OCT
30.00  40.00   50.00  60.00   70.0
         NOV
80.00

-------
                                                                             TU
                                flBURE C-Z


                        DETAILED STOftM PIOT OF  TRC HZO MODEL
U>
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             s °

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                CM

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              co
              u-
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                CFOO   TOO   4?00   OO   BiOO  10.00  12.00  14.00  16.00  TOO  20.00  22.00  24.00  26.00
                        3AM
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-------
                                                          IT
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     C\J
        !).00  10.00    20.00    30.00    40.00    50.00    60.00    70.'00 360.00

                   OCT                       NOV

                           FIGURE 6-3:  UAMPt.E PLOT Of QUAl ITAIIVE OU1PUT
                                                                                  o
                                                                                  o
  --OUTFLOW  STREAM  (cfs)


o—ACID  IN  OUTFLOW STREAM (Ibs)
                  1316-005

-------
            7.0  DESCRIPTION OF FIELD PROGRAM AND INTERFACE WITH MODEL

                          7.1   Outline  of  Field  Program

     Following  initial  model  development  TRC will  begin a phased  field  pro-
 gram for coal  pile  runoff from utility  sites.   The objectives of  this  pro-
 gram are:


     1)    To obtain representative data to fine tune and modify  the  coal  pile
          runoff model.

     2)    To test  the  runoff model  for a variety  of  climatic regimes,  coal
          pile  configurations,  and coal characteristics.

     3)    To generate a substantial data  base  on  Che quantity and quality of
          coal  pile runoff from various utility  sites throughout  the  country.


     The  proposed  field program  will  be  conducted  at  12  different utility
 sites  nationwide   over  a  2  1/2  year  period.   The  first two  locations will
 serve  as test  sites  and  the data will be  used to  fine  tune and modify the
 model.   These  two sites will also serve to refine  the field  program for the
 remaining  ten  sites.   The field  survey at the ten sites will be used to  test
 the  runoff model  for  a  variety  of  climatic  regions, coal  pile configura-
 tions,  and coal  characteristics as  well as  generating a  substantial data
 base  on  coal pile runoff.   The  field  program  for  each site will  vary from
 one  month to 9  months.
                          7.2  Parameters of Interest

    During the  field  program at  each  site,  TRC will take continuous measure-
ments of flow,  pH, conductivity, and temperature.

    In  addition,  samples  will be taken  of  the runoff  flow  periodically and
analyzed  for acidity,  alkalinity,  TSS,  TDS,  TOC, sulfate,  hardness,  iron
and 19  trace metals.

    A small  meteorological station will  be erected at  each  site  to measure
precipitation, air temperature, solar radiation and evaporation.


                              7.3  Data  Reduction

    All strip charts  from the continuous monitors will  be digitized  to pro-
duce magnetic tapes of  site  data.   The  tape of the runoff flow volume can be
read into  the model  to plot a comparison  of  simulated and  recorded  flows.
All laboratory  analysis will be reduced, evaluated statistically  and  placed
on magnetic tape.
                                      372

-------
                     8.0  COMPUTING  DESIGN CHARACTERISTICS
                                8.1  Data Bank
    All  of the  data  collected in  the  field program will  become part of  a
computerized  data bank.   The data  can be  used  by utilities  which do  not
choose  to simulate their coal pile  runoff but  rather would be  interested in
evaluating  data  from  a site  with   similar  coal  pile characteristics.   The
data  can be used to determine possible  waste characteristics and volumes  for
treatment system design.


                         8.2  Coal Pile  Drainage Model

    The  model, calibrated  and verified under a number  of  field conditions,
can  be used  to  simulate different  coal pile drainage  situations.  Using  se-
veral years  of  historical  meteorological  data,  the   model  can  determine
"average" flows  and  pollutant loadings.  The  model  also has  the  option to
read  in  selected precipitation data  from  a  card  deck.   The user can create
different combinations  of  dry days and  storm events  to  evaluate  when  the
highest  pollutant loadings occur.  In addition, the plots of detailed storms
will  show when and if the  "first flush" of  pollutants occurs and when runoff
flow  concentrations are  low enough  to be discharged without  treatment.

     From this analysis of both average and worst case conditions, collection
basins and treatment  works  can be more  accurately designed  and sized.
                                        373

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                       9.0  SUMMARY OF UPCOMING ACTIONS

    As of  May  1980 TRC  has  completed initial  model  development,  the  field
program design,  and  a manual of  field  procedures.   TRC is working  with  in-
terested utilities,  EPRI, EEI,  and EPA  to  locate  test  sites.   Data  from
these field programs will be used  in model  calibration and verification.   By
the end of  1981 the model should be useable as  a valuable  predictive tool  in
coal pile drainage characterization.
                                      374

-------
                     EMISSIONS  AND  EFFLUENTS

                             FROM

                    RAIL  AND  TRUCK  TANKCARS
                         T.  R.  Blackwood
                        Monsanto Company
                     800 N.  Lindbergh Blvd.
                      St.  Louis, MO  63166
                            ABSTRACT
As many as 700 different commodities are  handled  by  rail  or
truck tankcars.  Approximately  37,000  railcars  and 5,000,000
tanktrucks are cleaned each year  by industry  and  service
companies.  Air emissions of hydrocarbons can be  as  high  as
2.4 kg for tankcars and 310g for  tanktrucks.  Viscosity and
volatility are the primary influencing factors  on emissions.

If untreated, cleaning solutions  from  this process could ex-
ceed 2,500 metric tons/year of  oil and grease in  the wastewater,
Hydrocarbon emissions to the air  could also exceed 620 metric
tons/year or about 0.0022% of U.  S. emissions.   Practical and
economically feasible control for1 air  emissions does not exist
except for combustible gases and  water-soluble  vapors.  State-
of-the-art technology for wastewater  effluents  does  exist but
the effectiveness is widely variable  and  is very  expensive.

This report describes the state-of-the-art practice  in mobile
tank cleaning.  Composition, estimated quantities, and rate of
emissions and pollutants are described along with control
methods and costs.
                                375

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INTRODUCTION

Various chemical  and  petroleum products are transported by rail
tankcars and  tanktrucks.   These shipping tanks must be cleaned
before being  used  to  ship  a  different material,  or contamination
of the new material could  result.   An experimental study (1)
was conducted by  Monsanto  Research Corporation to obtain prelim-
inary estimates on air  emission and water effluent from the
cleaning process.  This  report assesses the impact and the
economics of  one  potential control technology system.

Rail tankcars and  most  tanktrucks  are in dedicated service
(carrying one commodity  only).   Unless contaminated,  they are
cleaned only  prior to repair  or testing.   Nondedicated tank-
trucks, approximately 22%  of  the total tanktrucks in  service,
are cleaned after  every  trip  to prevent cross contamination.
The approximate total number  of units cleaned per year are
37,000 rail tankcars  and 5,010,000 tanktrucks.

Steaming, washing  and/or flushing  of the tanks result  in air
emissions and wastewater effluents.   These cleaning operations
are partially enclosed.  Residual  material is usually  washed to
the wastewater collection  system,  and only small amounts of
material escape through  the vents  to the atmosphere.

Air emissions from cleaning of tanks are predominately organic
chemical vapors.   As hydrocarbons,  these emissions represent
less than .0022% of the  national emissions of hydrocarbons.
Water pollutants  from cleaning of  tanks are primarily  oil and
grease, suspended  solids,  and  phenol.   Uncontrolled water
effluent quantities from this  source are summarized in Table 1.

          TABLE 1.  POTENTIAL  WATER POLLUTANTS FROM
                    RAIL TANKCARS,  TANKTRUCKS,  AND
                    DRUMS  (metric  tons/yr)
                    (Estimated  in  reference #1)
   Source type
      (basis)          Oil and grease    Suspended solids   Phenol
Rail tankcar cleaning
(37,220 cars/yr)
Tanktruck cleaning
(5,010,000 trucks/yr)

830

1,745

4,100

6,070

31

986
SOURCE DESCRIPTION

There are approximately 178,000 rail  tankcars  and 90,000 tank-
trucks in service in the United States.   Most  of the tanks are
owned privately and haul liquids.   These  privately owned tanks
are not cleaned as often since they generally  can be used for

                               376

-------
dedicated  service.   Leased  tanks,  on the other hand, are cleaned
nearly every  trip.   The  amount of  cleaning that is conducted
depends upon  the  operational  practice of the cleaning site, the
chemicals  being removed,  and  the size of the tank.  The quantities
used  per tank truck  vary from approximately 0.23 cubic meters
(sixty gallons) for  steam operations to 20.9 cubic meters  (5,500
gallons) for  full flushing, with two cubic meters  (500 gallons)
being considered  the average.  The average amount of material
cleaned from  each tanktruck is estimated to be 100 kilograms.
Vapors from volatile materials are flared at a few terminals, but
the most common practice is to allow them to dissipate into the
atmosphere.

The amount of liquid used per rail tankcar varies  from 0.23 cubic
meters for steam  cleaning to  129 cubic meters  (34,000 gallons)
for total  flushing of a large tank car.  The average amount of
residual material cleaned from a tankcar is estimated to be to  250
kilograms.  Vapors from cleaning tank cars used to haul volatile
materials  are sent to flares  at some cleaning  facilities.  Vapors
of materials  such as anhydrous ammonia and chlorine are dissolved
in water and  become waste water constituents.  Vapors not  flared
or dissolved  in water are dissipated into the  atmosphere.

Tables 2 and  3 summarize the typical variety of chemicals  cleaned
from  tanktrucks  during a one-month period along with  the  fre-
quency of  the type of cleaning methods.  The most  common  cleaning
practice  is the  use of steam, although most commercial  cleaners
utilize a  water  rinse before and after the  steam  cleaning.   As
shown in Table 3, the determination  of emissions  and  emission
factors is complicated by the cleaning methods.


           TABLE  2.  TRAILER  INTERNAL CLEANING  GENERATION  RATES
                     FOR ONE  TERMINAL DURING ONE  MONTH OF
                     OPERATION  C2)
Method Water use,
Dumber Cleaning method m-y trailer
1
2
3

4

5

6
7

8

Cold water flush
Cold water flush — caustic/acid tank
Cold water flush — steam — cold water
rinse
Cold water flush — spin/detergent —
cold water rinse
MEK, MIBK,a or acetone solvent — cold
water rinse
Styrene solvent — cold water rinse
Cold water flush— steam— cold water
rinse — spin w/detergent— cold water rinse
Cold water flush w/Butterworth for
dry bulk trailer
0.57
8.3

3.0

1.1

0.57
0.57

3.6

5.7
Number of
trailers
84
321

316

123

0
0

68

78
Total water
use, ro-*
47.6
2,666.0

954.5

139.3

0
0

243.9

441.7
TOTALS                                                   990     4,493.3
                                  377

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          TABLE 3.  COMMODITY/TANKTRUCK DATA FOR ONE TERMINAL
                    DURING ONE MONTH OF OPERATION (2)
Cleaning
 method
 number
Commodity
 No. of
trailers
cleaned
            Uran fertilizer
            PAPI—isozylate
            Ethyl chloride
            Alum
            Water for glue
            Water softener

            Caustic soda (50%)
            Silicate soda
            Acetic acid
            Phosphoric acid
            Spent acid
            Sulfuric acid
            Hydrochloric acid
            Corrosive liquid

            Solvent
            Toluene
            Xylene
            IPA—isopropyl alcohol
            Sodium MET
            EDA—ethylene diamine
            DTA—diethylene triamine
            Poly amines
            Vinyl acetate
            Cyescal
            Phenol
            Alcohol
            Petroleum chemicals
            Peroxide
            Biphenyl
            Sodium bichromate
            Sodium methylate
            PA-phthalic anhydride
            Acetone
            Adaline
            Ferric chloride
            TTA—Amine 220
            AN—acrylonitrile
            Protein feed supplement
            Calcium chloride
            Styrene
            Methyl acrylate
            Weed killer
            Shell pan
            DMK—dimethyl ketone
                                 16
                                  2
                                 10
                                 53
                                  2
                                  1

                                123
                                  2
                                 22
                                  1
                                 47
                                 87
                                 38
                                  1

                                 18
                                 26
                                  2
                                 23
                                  1
                                 15
                                  8
                                  7
                                 23
                                  3
                                 32
                                 22
                                  1
                                  4
                                  2
                                  9
                                  3
                                  6
                                  9
                                  4
                                  3
                                  3
                                  8
                                  2
                                  1
                                  2
                                  1
                                  4
                                  1
                                  4
                                378

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                       TABLE 3 (Continued)
Cleaning
 method
 numbera
Commodity
 No. of
trailers
cleaned
 3(cont.)   Benzene                                       1
            Pentylamine                                   1
            Ethylene glycol                               3
            MEK—methyl ethyl ketone                     14
            ITA                                           2
            Mineral spirits                               3
            DAA—diacetone acrylonitrile                  4
            NBA—normal butyl alcohol                     1
            Methanol                                      3
            Butyl cellosolve                              1
            Formaldehyde                                 24
            Oxylene                                       1
            Naphtha                                       1
            MIBK—methyl isobutyl ketone                  4
            Demineralized water                           1
            Turpentine                                    2
            Oxital—ethylene glycol monoethane ether      1
            TRI Clean D                                   2

   4        Glue                                         72
            Paint                                         2
            Resin                                        30
            Water treating compound                       5
            Coastal pale oil                              7
            Petroleum oil                                 3
            Cotton oil                                    2
            Script set                                    2

   7        Diesel oil                                   21
            Petrolatum                                   16
            Ink oil                                       2
            Strip oil                                    13
            Hi Boiler Oil                                  2
            Tall Oil                                       5
            Insulator oil  (.new).                            1
            CPTIC—crude petroleum                        8

   8        Potash and  fertilizers
            Plastic pellets                               78
 a Cleaning method numbers correspond to those tested in Table 2
                                 379

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AIR EMISSION

The great diversity  of commodities  (over 700 chemicals)  carried
by rail tankcars  and tanktrucks makes it nearly  impossible  to
sample and obtain emission factors for every possible  material.
Sampling of emissions from the cleaning of selected  commodities
was conducted  to  obtain an indication of the relative  amounts of
various types  of  materials.   In order to achieve  a representative
picture, the organic chemicals were broken down  into classes
cliaracterized   by high, medium, and low viscosities  and  by  high,
medium, and low vapor pressures at ambient temperature.   Viscosity
affects the quantity of material which remains in the  tank  since
low viscosity  materials would drain more easily  than high vis-
cosity materials.   It was anticipated that the higher  the vapor
pressure the higher  the air  emission rate would  be during clean-
ing.

It has been reported that virtually all the air  and  water pollu-
tants are removed from the tank during the first  washing cycle.
This takes 45  minutes to one hour for tank trucks and  one to
two hours for  rail  tankcars.  Subsequent rinsing  adds  only  small
(less than 2%)  quantities of waste to the wash water.  The
measured emissions  from tankcar and tanktruck cleaning are
summarized in  Table  4.   Using these data and a Gaussian  dispersion
model, the impact of a typical cleaning facility  on  ambient air
quality can be  estimated.   In its simplest form,  the dispersion
model for the  calculation of the maximum ground  level  concentra-
tion is (3) :
      max
             irH  eU
          TABLE  4.   MEASURED EMISSIONS FROM TANK-
                     CAR  AND TANKTRUCK CLEANING




Compound
Acetone
Perchloroethylene
Methyl methacrylate
Phenol
Propylene glycol
Ethylene glycol
Chlorobenzene
o-Dichlorobenzene
Creosote


Chemical

Vapor
pressure
High
High
Medium
Low
Low
Low
Medium
Low
Low


class


Viscosity
Low
Low
Medium
Low
High
High
Medium
Medium
High




emissions.
ga
311/truck
215/truck
32.4/truck
5.5/truck
1.07/truck
<0.32/car
15.7/car
75.4/car
2,350/car
(8-hr)
Measured
emission
concen-
tration,
mg/m3
654
526
79.1
14.0
4.3
<0.2
8.8
94.3
118

 Total emissions =  (emission rate) x (emission volume).
                                 380

-------
where:  Q = mass emission  rate,  g/s

        U = U.  S. average  wind  speed,  4.47 m/s

        H = emission  height,  m

        e = 2.72

        IT = 3.14


Since  the average emission height is about four meters, the
maximum ground  level  concentration for each chemical would be
as  shown in Table 5.   These maximums are based on cleaning
thirty tanktrucks or  five  and one-half tankcars each day.  It
is  rare for more than one  truck or car to contain the  same chem-
ical in any one day.   Each maximum ground level concentration
shown  in Table  5 represents the worst case for a typical  facili-
ty  (cleaning  only one chemical  over a long period of time).   In
addition, this  maximum can be shown to occur within twelve to
forty  meters  from the tank being cleaned.

The concentration at  the plant  boundary would  be considerably
less than the maximum value since concentration decreases by the
inverse of  the  square of the distance from the source.  Compared
to  the ambient  air  quality standard for three  hours of 160 micro-
grams  per cubic meter, the typical cleaning  facility is not
likely to result  in a violation of the ambient air quality stan-
dard.  A more rigorous analysis could be conducted utilizing the
distribution  of commodities cleaned at each  facility.   However,
additional  study  was  not warranted since the  worst case analysis
showed that the present impact is very small.

          TABLE 5.   MAXIMUM GROUND LEVEL CONCENTRATIONS FOR
                   DIFFERENT EMISSIONS
    Type of                                          Xmax'
   cleaning                  Emission                yg/m3


 Tank truck     Acetone                               359
                Perchloroethylene                    248
                Methyl methacrylate                    37
                Phenol                                  6.35
                Propylene glycol                       1.24

 Rail tank car  Ethylene glycol                        <0.14
                Chlorobenzene                          7.14
                o-Dichlorobenzene                      34.3
                Creosote                             267
                                  381

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From another perspective,  if  the highest emission factor for
tanktrucks and  tankcars  Cacetone)  is applied to all of the tanks
cleaned,  the total  emissions  of  hydrocarbons for tanktrucks and
rail cars would be  538 and 87 metric tons per year, respectively.
This corresponds to less  than .0022% of the total hydrocarbons
emissions in the U.  S.  Based upon this evidence, it has been
concluded that  air  emissions  from the cleaning of rail tankcars
and tanktrucks  are  not significant emission sources.

WATER EFFLUENTS

Waste water collected in  a tank  cleaning facility is subject to a
great variability.   Even  with a  good treatment system, it is diffi-
cult to treat to consistently acceptable levels.  Table 6 sum-
marizes the effluent characteristics of a slightly larger than
average tanktruck cleaning facility.   This facility is a forty-
five cubic meter per day  (.12,000 gallons per day) demonstration
plant funded by the  U. S.  EPA (4).   Also shown in Table 6 are
the approximate levels that have been achieved in the effluent
of this experimental system.   A  schematic of the system is shown
in Figure 1.  Utilizing these data  and other available infor-
mation, an analysis  was conducted  on the uncontrolled effluent
concentrations  resulting  from representative sources.  A more
detailed description of this  analysis is given in Reference 1.
The results, which  are summarized  in Table 7 show that the
effluent concentrations are especially high for oil and grease,
and phenol.  Further analysis shows that the impact on typical
receiving waters  is  minimal.

To estimate the impact of  an  effluent on water quality, the
concept of source severity was developed.  Source severity is
defined as the  pollutant  concentration to which aquatic life is
exposed, divided  by  an acceptable  concentration.  The exposure
concentration is  the fully-diluted  receiving water concentration
resulting from  the  source.  The  acceptable concentration is de-
fined as the concentration at which it is assumed that an incip-
ient adverse environmental impact  occurs (.usually the water
quality criterion}.  Mathematically expressed, this is:

     B _  CW  CD
     O "~ ••—' i i i •"   • '»	»
where

     CD = concentration in raw effluent,  g/m

     F  = fresh water criteria, g/m
     V  = volumetric flow rate of discharge,  ra /sec
                                                      o
     VR = volumetric flow rate of receiving  waters,  m /sec

     S  = dimensionless
                              382

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          TABLE 6.  TREATMENT PLANT  OPERATING RESULTS —
                    MATLACK, INC., SWEDESBORO, N.J.   (4)

Parameter
PH
Color units
Turbidity, FTUa
COD, g/m3
BODs, g/m3
Oil and grease, g/m
Phenols, g/m3
Suspended solids, g/m3
Raw
10.5
Over
Over
1,800
600
110
1
300
feed
to
12.5
500
Effluent
6.5
10
500
to
to
to
to
to
11,000
2,000
350
250
1,300
125
20
0


to
t0u
_b
to
to
to
0,1
"
8.5
50

300
100
1



 Forraazin turbidity units;  a  standard unit of turbidity based
 upon a known chemical reaction

3Data not reported.
          TABLE 7.   EFFLUENT CONCENTRATIONS FOR
                    REPRESENTATIVE SOURCES
Source
Rail tank cars
Tank trucks
Effluent
Oil and
grease
2,005
230
concentrations, g/m3
Phenol
75
130
Suspended
solids
10,025
800
Flow,
m3/day
61
45
          TABLE  8.   SOURCE SEVERITIES FOR REPRESENTATIVE SOURCES
  Source type
Oil and
grease
                               Source severity,  s
Suspended
  solids
Phenol
Rail tank car      0.16
Tank truck         0.014
                     0.00033
                     0.000020
                    0.062
                    0.080
                                  333

-------
Table  8  is  a summary of  the  severities for  the  effluents from
a representative cleaning  facility.  From this  analysis, the
exposure concentration is  found to be less  than the fresh water
criteria (severity < 1.0)  even from the uncontrolled effluents
into U.  S.  Average river flow (1).

The state total discharge  rates of oil and  grease,  phenol, and
suspended solids, assuming no treatment, were calculated by:
dividing the production of the representative source into state
production  totals and multiplying  this figure by the discharge
rate per representative  source.   These quantities are given for
each state  in Reference  1.   Table  9 summarizes  the estimated
uncontrolled emission burdens due  to rail car and tank truck
cleaning for selected states.
  RAW WASTE
          SURFACE
          SKIM OIL
             RESALE)
                     FLOTATION
                      /CELL
           pH  PRESSURE   f
           1
         ROLLINS ENV.
          SERVICES
        CLARIFIER


BIOLOGICAL
OXIDATION






P
V
                                        ACTIVATED
                                        CARBON
                                        TRANSFER
                                        TANK
                                           ADSORBERS'
                                   SPENT CARBON
       DISCHARGE
RECYCLE
        FIGURE 1.  Wastewater Treatment  System, Matlack,  inc.
                   Swedesboro, New Jersey C4>.               *'
                               384

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        TABLE a.   PROJECTED RAIL TANKCAR AND TANKTRUCK
                  CONTRIBUTION TO STATE.-EMISSION BURDENS
Rail Tankcars


State
Arkansas
California
Illinois
Indiana
Kansas
Louisiana
Ohio
Texas
U.S.
Totals


Cars/yr
3000
2000
2000
4750
5000
2500
1750
5500

37,220
Oil and
grease
tons/yr
67
44
44
106
110
56
39
120

830
Suspended
solids
. tons/yr
330
220
220
530
560
280
194
610

4100
Phenol

tons/yr
2.5
1.7
1.7
3.9
4.2
2.1
1.5
4.6

31


Tanks/yr
90,000
240,000
290,000
220,000
172,000
250,000
200,000
400,000

5,010,000
Tanktrucks
Oil and
grease
tons/yr
31
84
101
77
60
87
70
139

1745
Suspended
Solids '
tons/yr
109
291
351
266
208
303
242
484

6068
Phenol

tons/yr
18
47
57
43
34
49
39
79

986
CONTROL TECHNOLOGY

This preliminary study indicates that control  of  air  emissions
from the cleaning of rail tankcars and  tanktrucks is  not necessary
except for combustible gases and water  soluble vapors such as
ammonia and chlorine.  Combustible vapors  are  usually sent to
flares and burned.  Vapors and materials  such  as  chlorine are
absorbed in water and sent to the wastewater stream.

Until the late 1960s, little attention  was given  to wastewater
treatment in this industry.  This inattention  resulted because
waters were generally low in volume,  installations were small,
and environmental impacts were considered  relatively  small in
comparison to those of other sources.   As  shown in the source
assessment (.1) , the severity of  the wastewater effluents is
quite small, especially in comparison to  other industrial
sources.

In recent years, several rail tankcar and  tanktruck cleaning
wastewater treatment facilities  have  been  upgraded in an effort
to meet environmental regulations.  However, no installation is
known to have a completely satisfactory treatment system.  Treat-
ment technology applicable to rail and  truck wastewaters is for
the most part well known.  However, the wide diversity in the
materials entering the wastewaters prevents the use of a single
specific treatment system by all companies. For this reason,
tank car and tanktruck cleaning  companies  are  approaching their
individual problems by using one or more  combinations of conven-
tional wastewater treatment methods.

Industry and tankcar manufacturers have developed new tank de-
signs which avoid the necessity  to clean the tank.  Of particu-
lar interest is the recent development  of diaphram tanks  (.5)
which can carry a different cargo each  way between plants.   The
diaphram prevents product contamination.
                               385

-------
 One  tank  truck  cleaning facility has had some success in the
 treatment of  a  wide  variety of chemicals in its wastewaters.
 However,  their  system,  shown in Figure 1, has not been able to
 get  the biological  treatment to work,  and problems still exist
 with the  COD  and  BOD levels.  The effluent concentrations ob-
 tained by this  experimental facility are even higher than those
 obtainable with the  same type of equipment on effluents from
 petroleum refineries.   This indicates  that the job of achieving
 comparable effluent  concentrations will be much more costly and
 require further developmental work.

 The  costs of  operating  a system similar to the one shown in
 Figure 1  are  summarized in Table 10.  At present, this type of
 effluent  cleaning system would cost  about $25.00 per tanktruck
 and  about $100.00 per rail tankcar.


           TABLE 10.   NET OPERATING COST  C1975) FOR THE 45
                      CUBIC METER PER DAY (12,000 GPD) WASTEWATER
                      TREATMENT FACILITY SHOWN IN FIGURE 1 (4).


 "                                                       $AOOO gal
 Labor     -  1 operator,  9  hr/day - 5 days/wk                4.93
 Carbon    -                                                  30.77
 Chemicals -   90%  cation polymer                             3.85
 Power     -                                                   0.77
 Depreciation  -                                             4.81
 Sludge disposal  -   40  gals/1000 gal wastewater             2.56
 Biological oxidation -                                       2.31
  TOTAL                                                     50.00
CONCLUSIONS

This preliminary assessment  indicates  that (.1)  air emissions
from the cleaning of rail tankcars  and tanktrucks are higher for
high vapor pressure.  High viscosity materials  will show higher
emissions due to the amount  of residual material and the clean-
ing method.   02)  The emissions contribution  to ambient air
quality degradation is insignificant for the  typical cleaning
facility.  The source assessment  study shows  that C31 waste
effluents do not pose a major impact on the water quality,  but
that a reduction will be required to be compatible with effluent
concentrations from other treatment processes.   Finally,  (4) the
resulting cost, with existing technology,  is  high compared to
the benefit.  Wastewater treatment  could be made potentially
                               386

-------
more effective by combining the stream to be  treated  with other
wastewater, equalizing load to the treatment  system.   In addi-
tion, the jase of diaphrams may reduce the amount  of cleaning
which will further reduce the present emissions and effluents.


REFERENCES

(1)   Early, D. E., K. M. Tackett, and T. R.  Blackwood.  "Source
      Assessment:  Rail Tank Car, Tank Truck,  and Drum Cleaning,
      State-of-the-Art", USEPA, EPA-600/2-78-004g, April 1978.

(2)   "Development Document for Proposed Effluent Limitations,
      Guidelines, and New Source  Performance  Standards for the
      Trucking Segment of the Transportation  Industry Point Source
      Category"; Office of Enforcement and  General Counsel,
      National Field  Investigations  Center,  Cincinnati,  Ohio,
      1975.

(3)   Slade, D. H.,  "Meterology and  Atomic  Energy",  U. S. Atomic
      Energy Commission.  TID-24190,  1968.

C4)   O'Brien, J.  E.   "A Demonstration  Plant for  the  Treatment
      of Waste Waters  from Truck  Tank Cleanings.   AIChE National
      Meeting, Atlantic City, N.J.    Sept.  1976.

(5)   Personal Communication, D.  E.  Fogelsanger of Goodyear
      Aerospace Corp.,  Sept.  15,  1978.
                                387

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                                                                      AV-TP-80/541

                      A NEW CONCEPT FOR THE CONTROL OF

         URBAN INHALABLE PARTICULATE BY THE USE OF CHARGED FOG

                                  John Scott Kinsey
                                        and
                                   Carol E. Lyons
                                 AeroVironment Inc.

                                  Stuart A. Hoenig
                                University of Arizona

                                  Dennis Drehmel
                        U.S. Environmental Protection Agency
             Industrial Environmental Research Lab, Research Triangle Park
             Presented at the EPA Fourth Symposium on Fugitive Emissions:
                              Measurement and Control
                       New Orleans, Louisiana, May 28-30, 1980
Mr.  Kinsey is  an Air Quality Engineer and  Ms. Lyons  is a  Project  Manager  in  the
Environmental  Programs Division  of  AeroVironment  Inc., 145 Vista  Avenue, Pasadena,
California  91107. Dr. Hoenig is a Professor of Electrical Engineering at the University of
Arizona, Tucson, Arizona  85721.  Dr. Drehmel is with the  U.S.  Environmental Protection
Agency's Industrial Environmental  Research Laboratory,  Research Triangle Park,  North
Carolina 27711.
                                    ABSTRACT
This paper is directed to those  scientists and engineers concerned with the control of
fugitive particulates in the inhalable size range (<15 um) from non-traditional sources in
the urban  environment.  A new type of electrostatically augmented spray nozzle (fogger)
is  described which is intended to achieve a target control efficiency of 90% for  inhalable
particulates.   The theory of operation is explained, along with a  physical model for
predicting the control efficiency of the fogger.  Results of preliminary wind tunnel  tests
are presented showing the degree of control actually achieved by the fogger  for various
operating  modes.  Finally, plans for additional modifications to the fogger are discussed
which incorporate the information gained from preliminary testing in the wind tunnel.
                                          388

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Introduction

           The use of electrostatic  precipitation  for the  collection of fine  particulate
matter is common engineering practice and is well-documented in the literature. '  More
recently, electrostatics  has, been jjsed  to augment  traditional  wet dust  collectors
(scrubbers) of varying design »''».  Since 1977, one  investigator  at  the University of
Arizona  has  been studying a  new  approach  for the application  of  electrostatically
augmented water  sprays (charged fog) on  a  bench scale for the control of fugitive dust
generated by various  industrial processes  ' . Commercial devices (foggers) resulting from
this  work  are now  available  from  a firm in Pennsylvania  .    These  foggers offer
significant economic  advantages over more  traditional  fugitive dust control  technology,
but also have problems which inherently  limit both  their effectiveness to  control fine
particulate and their applicability to control fugitive dust  from certain types of sources.
A more detailed discussion of these problems will be presented later in this paper.

           In recent  months, the  health-related  problems  associated with suspended
particulate matter in the inhalable size range (< 15 um  aerodynamic diameter) have been
of rising concern.   The U.S. Environmental Protection  Agency plans to  develop and
promulgate a size-specific ambient air quality standard to address the  inhalable particu-
late  problem in  the  near  future.   If such a revised ambient air quality  standard is
promulgated, it will necessitate even greater degrees of control for nontraditional as well
as traditional sources of particulate emissions, especially  for  those sources in the urban
environment where the problem is most acute.

           This paper  will describe a  new type of electrostatically  augmented  spray
nozzle (fogger) for the control of urban inhalable  particulate. The  new fogger  has been
designed to  eliminate  the major  operational  problems  associated  with  conventional
equipment and is intended to achieve a target control efficiency of 90% for  particulates
in the inhalable size  range. The  Spinning Cup Fogger Thrower (SCFT),  as it is called,  will
eventually be used to control emissions from mobile sources  representing the major
contributors  to the inhalable particulate problem in the urban environment.

           The following discussion  presents the  theory of operation  and design of  the
SCFT, along with the results of preliminary wind tunnel  tests conducted on the original
prototype. A modified SCFT is currently under development which incorporates a number
of design changes based  upon  the experimental  data  reported  below  and  will likewise
undergo detailed testing in the near future.

Theory of Operation

           Experiments  have  shawn that  most   dust  is  electrically  charged  and that
generally the charge is  negative .  By producing a positively charged spray, the dust
particles are attracted to the water  droplets, and the number of particles which the water
drops will collect by impaction without electrical effect  is increased  substantially when
the  drops and particulate are of opposite charge. The agglomerated  particles of mixed
droplets and particulates will settle out according to the Stokes relationship.

           A relationship describing  the  overall  collection efficiency  of  suspended
particulate matter by water droplets has been described by Calvert  and later by Cheng
and  can be expressed as:
                                           389

-------
                            E  - 1 - exp

where:

           E    -    Overall collection efficiency
           Q.   =    Liquid volumetric flow rate
           Q    =    Gas volumetric flowrate
           t &   =    Contact  time (or  characteristic  length for  the total capture
                     process)                                                  ^
           D .   =    Sauter mean droplet diameter
           TI    -    Single droplet target efficiency

           From the above expression it can be seen that  the single droplet efficiency, 77,
is  the most important determining factor in the control of fine particulates.  The single
droplet efficiency depends, to a large extent, on the unit mechanism, or mechanisms,  by
which the  particles are captured, and  which  of  these dominate.  Such  unit mechanisms
include direct interception; inertial impaction; Brownian diffusion; and the electrostatic,
magnetic, diffusiophoretic, and thermophoretic forces on the particles  '   '  .

           A detailed physical model has been developed by Grover and other collabora-
tors for the scavenging of atmospheric  aerosol particles by charged free-falling raindrops.
It  was determined that this model best  describes the singJe .droplet efficiency in terms of
all the various capture mechanisms and forces involved   '  '   .  The development of the
model is quite complex and thus  is being included in this paper by reference only.

Description of the Spinning Cup Fog Thrower

           The SCFT consists  of three main components,  each  serving  a particular
function.  These components are a rotary atomizer, an ionizer, and a vane-axial blower.
The rotary atomizer  is comprised of a small hollow-shaft motor and spinning cup.  Water
from a low-pressure source is introduced into the hollow shaft and flows  toward the other
end  where  the spinning cup is  mounted.  Upon entering the rear of the cup the water
stream strikes a rotating spider  which deflects the water  to the sides.  A sheet of water
then flows toward the lip of the cup  where droplets are  formed by centrifugal  force
normally leaving the  edge  of the  cup tangentially.  The  droplets are then charged by a
stream of  positive ions produced by  an  ionizer  containing numerous  small  discharge
needles.  Current to the ionizer  ring is supplied by a vacuum tube high-voltage DC power
supply.  The charged  fog droplets are then deflected and projected  forward  by a flow of
air supplied by the vane-axial blower into which the ionizer and rotary atomizer have been
mounted.   A diagram of the SCFT used during the wind tunnel tests described below is
shown in Figure 1.

           As was previously stated, the commercially  available foggers have  certain
problems inherent in their design which not only limit their application to certain types of
sources, but can also  severely limit the degree of control  achieved on fine particles.  The
first of these problems is that the existing foggers use either a standard pressure-type  or
twin-fluid nozzle to  atomize the water, thus necessitating a substantial supply of high
pressure water or air  for proper atomization.  In addition, these types of nozzles have a
tendency to clog if the water supply contains a high  concentration of  suspended  solids.
This problem has  been eliminated in the SCFT by a rotary atomizer which needs  neither
                                         390

-------
compressed air nor water pressure to generate a fog of fine water drops.  In addition, a
rotary atomizer is insensitive to any solids found in the water supply.

           The second and more severe problem with existing equipment involves the type
of charging mechanism being used. The existing foggers use an induction ring which tends
to charge only those droplets on the outside of the spray  cone  during heavy sprays with
the remaining droplets having little  or no charge.  Since the electrostatic attraction of
dust to water droplet  is critical to the  efficient  capture and agglomeration of fine
particles,  this is  a significant  problem.   The  SCFT  solves the problem by  using direct
charging which effectively  charges  most, if not all, of the droplets  generated by the
atomizer, significantly increasing its potential  to control  particles in the inhalable size
range.  By these  two basic  modifications, the SCFT is expected to have greatly reduced
water and power  consumption over previous equipment, in addition to being able  to more
effectively control emissions from mobile sources.

Experiment

           In order to verify theoretical relationships with experimental data, a series of
tests were conducted in a 4-foot  by 4-foot  by 60-foot wind tunnel  provided by  the
University of Arizona.   A standard  dust (AC Coarse) of known particle size and density
was pneumatically fed into the entrance of  the  tunnel  by a  Vibra-Screw feeder and
compressed  air which  was homogeneously mixed  with the incoming  ambient air by  a
diffuser cone.    The  SCFT  was  mounted  approximately  two  equivalent diameters
downstream  of the  tunnel  entrance  with the  fog  and air in cocurrent flow.  Plexiglas
viewing ports in both sides of the tunnel  were provided at the discharge end of the fogger
so that the wet/dry interface could  be more  closely observed.  Two sets of sampling ports
were provided in the  front  vertical wall of  the  tunnel; one set, approximately two
equivalent diameters downstream of  the discharge end of the fogger, was for determining
charge/mass ratio and droplet size, and the other set at the far end of  the tunnel was for
determining   particulate  mass concentration  and  size.    An axial  blade  fan  pulled
approximately 18,000 dscf/min of  air   through the  tunnel.   Figure 2  is  a schematic
representation of the University of Arizona wind tunnel.

           To determine the control efficiency of  the fogger under various experimental
conditions,  particulate  samples were  collected according to the test  plan shown  in
Figure  3. A  sample train was especially  designed for this purpose to isokinetically extract
a representative sample  of particulate  matter from  the wind  tunnel.   The sample   was
later analyzed gravimetrically  to  determine  both  the  total  mass concentration  and
particle size distribution for each  test scenario.   This train  consisted of  a pitobe  and
associated inclined  manometer connected  by  a  flexible sample line  to a horizontal
elutriator.  The  elutriator was originally designed to have a 15 urn particle diameter cut-
point (50% efficiency) at a flow of 20 scfm.  Behind the elutriator was mounted a standard
Sierra  Instruments five-stage  cascade impactor which discharged to a silica gel trap for
the determination of moisture content.  The  flow  was measured by  an  NBS-traceable
 Laminar Flow Element manufactured by the Meriam Instrument Company.  The Laminar
 Flow Element was located  downstream of the  silica gel trap and connected to a standard
 Dwyer magnahelic gauge for reading differential pressure. The flow rate was metered  by
a large capacity needle valve located downstream  of  the Laminar Flow Element followed
 by a Cadillac centrifugal blower acting as  prime mover.  A photograph of  the sampling
 train with the various components is shown in Figure 4.
                                          391

-------
           For sample  recovery,  the  front  portion of the sample train and  horizontal
elutriator were rinsed with de-ionized water into separate plastic  sample  containers for
transport  back to the laboratory.  There  the liquid/particle  mixture was quantitatively
transferred  to tared beakers and evaporated  to dryness  to  determine the  total  mass
collected.   The samples  were then resuspended in distilled  water and deagglomerated
ultrasonically.   The  particle size was  determined by a  Leeds <5c  Northrup  Microtrac
Analyzer using a ruby laser and forward-scatter optical technique.  The samples collected
on  the  various cascade impactor stages  were  also  analyzed gravimetrically  using  a
standard analytical balance.

           The  charge-to-mass  ratio  was  determined using  a  special  sample  train
developed by AeroVironment according to  a  method provided  by  Dr. Hoenig  at the
University  of Arizona.   This train consisted  of an insulated  stainless steel probe tip
mounted on a standard  glass midget impinger.   The probe  was connected electrically to
copper  wool packing placed inside the midget impinger which  also was connected by a
shielded cable to  an  electrometer (Hewlett-Packard Model <*25A) and associated strip-
chart recorder.  The impinger was immersed  in a Dewar  flask containing dry ice.   A
sample  of fog droplets was then  isokinetically extracted from the tunnel through the
sample  ports at the discharged end of the fogger. As the droplets moved through the
impinger they were condensed out of the gas stream and frozen,  thus transferring their
charge to the copper wool packing.  The charge  was then measured by the electrometer
and recorded by the chart recorder. The mass of water collected in  the impinger was then
determined  gravimetrically at the end of each  test  run using a  portable triple-beam
balance. Isokinetic conditions were maintained by a Hastings  mass  flowmeter and needle
valve with a standard diaphragm pump acting as prime mover. A standard pitot tube and
associated inclined manometer were mounted next to the impinger/Dewar flask assembly
with adequate distance between them to avoid aerodynamic interference.

           The size of the droplets was measured simultaneously with the charge-to-mass
ratio  by a KLD Model DC-2 droplet  counter.   This unit uses a hot-wire technique to
measure-the size  of the  droplets in 1* incremental ranges from  1 um to greater than
450 um   '   .  The hot-wire probe was  mounted a sufficient distance from the impinger to
avoid aerodynamic interference with it or the pitot tube used to measure the gas velocity.

Results

          Data obtained from the first series of tests, as described above, of the total
mass  concentration measured for  various experimental conditions are shown  in Figure 5
for a  low dust feed rate to the tunnel, and in Figure 6 for a  high dust feed rate.  It was
also determined during the course of sample collection that larger, agglomerated particles
which could not settle out of the gas stream in the tunnel due to the high  velocity were
being collected in the first bend of the sample probe. For this  reason, Figures 5 and 6 also
show  a second value, where available,  for  the total amount of particulate matter caught
by the sample train less the  larger particles collected in the probe.

Conclusions

          From the data presented in Figures 5 and 6, it  can be seen that a significant
reduction  in  dust  concentration can be achieved with the SCFT,  but that it does not
currently meet the 90% target efficiency.  It can also be determined that the fog droplets
                                         392

-------
must have a high  charge-to-mass ratio for effective  control of fine paniculate and, as
would be  expected, that uncharged  fog or  fog with little electrostatic charge  does not
provide  nearly as good results.

           Based upon these conclusions, it was decided that certain modifications to the
design of  the fogger or  to the operation of the wind tunnel were necessary to determine
the optimal  effectiveness of the SCFT under  controlled  conditions in relation  to the
target  results.   For this reason, the velocity of the gas moving through  the tunnel was
reduced to  allow  the larger particles to settle out and to increase the particle/droplet
contact time. It was also determined that major design changes to  the ionizer  would be
necessary to increase the charge-to-mass ratio.

           A second  prototype  of the SCFT  is currently being  fabricated which  will be
tested in  the wind tunnel at University  of Arizona  in the near future.   The  modified
version  will  include a  completely redesigned atomizer to provide  more  effective spray
pattern.  It also incorporates a  new method for  charging the droplets which preliminary
data show to be markedly more effective. It is anticipated that the modified SCFT will
easily meet the  required target efficiency during the upcoming tests.
 Metric Conversion Factors for non-metric units used in text:

 1 foot           =     0.3048 m
 1 dscf/min       =     0.0283 dscm/min
 1 scf m          =     0.0283 scm/min
 1 gr/dscf        =     2.2883 gm/dscm
                                          393

-------
 References

 1.    H.J.  White,  Industrial  Electrostatic Precipitation, Addison-Wesley,  Reading, MA
       (1963).

 2.    HJ.  White, "Electrostatic precipitation of fly ash," 3APCA, 27 (1): 15-21; (2): 114-
       120; (3): 206-217; (4): 308-318 (1977).

 3.    D.C.  Drehmel, "Advanced electrostatic collection concepts," 3APCA, 27 (11):  1090-
       1092  (1977).

 it.    M. Pilat  and D.F. Meyer, "University  of Washington electrostatic spray scrubber
       evaluation," EPA-600/2-76-100 (NTI5 PB 252653), University of Washington, Seattle,
       WA (1976).

 5.    C.W. Lear, "Charged droplet scrubber for fine particle control:  Laboratory study,"
       EPA-600/2-76-249a  (NTIS PB 258823),  TRW  Systems Group,  Redondo  Beach, CA
       (1976).

 6.    W.F.  Krieve and J.M. Bell, "Charged droplet scrubber for fine particle control: pilot
       demonstration," EPA-600/2-76-249b (NTIS PB 260474), TRW  Defense and  Space
       Systems Group, Redondo Beach, CA (1976).

 7.    S. Calvert,  3. Goldschmid, D. Leith, and D. Mehta,  "Wet scrubber system  study
       Volume  1,   scrubber  handbook,"   EPA-R2-72-118a  (NTIS PB  213016),  Ambient
       Purification Technology, Inc., Riverside, CA (1972).

 8.    S.A.  Hoenig,  "Use of electrostatically  charged  fog  for  control  of  fugitive dust
       emissions," EPA-600/7-77-131 (NTIS PB 276645), University of Arizona,  Tucson, AZ
       (1977).

 9.    S.A. Hoenig, "Fugitive and fine particle control using electrostatically charged fog "
       EPA-600/7-79-078 (NTIS PB 298069), University of Arizona, Tucson, AZ (1979).

10.    Ritten  Corporation,  Stop  Dust Pollution,  manufacturer's  brochure, Ardmore, PA
       (1980).

11.    L. Cheng, "Collection of airborne  dust  by water sprays," Ind.  Eng. Chem.  Process
       Des.  Develop., 12 (3): 221-225 (1973).

12.    S.N. Grover, H.R. Pruppacher, and A.E.  Hamielec, "A numerical determination of
       the efficiency with which spherical aerosol particles collide with spherical  water
       drops due to inertial  impaction and phoretic and electrical forces," 3.  Atmos. Sci
       34: 1655-1663(1977).

13.    K.V.  Beard  and S.N. Grover, "Numerical  collision efficiencies for small  raindrops
       colliding with micron size particles," 3. Atmos. Sci., 31.: 543-550 (1974).

14.    S.N. Grover and K.V. Beard, "A Numerical determination  of the efficiencies with
       which electrically  charged cloud drops and small raindrops collide with  electrically
                                          394

-------
      charged  spherical particles of various densities," 3. Atmos.  Sci., 32: 2156-2165
      (1977).

15.    H. Medecki,  K.C. Wu,  and D.E. Magnus,  "Development of droplet sizing for the
      evaluation of scrubbing systems,"  EPA-600/7-79-166  (NTIS PB 80-10857^),  KLD
      Associates, Inc., New York, (1979).

16.    D.E. Magnus, H. Medecki, and K.C. Wu, "Sensing of droplet size and concentration in
      pollution control equipment," Proceedings of the 4th Joint Conference on Sensing of
      Environmental Pollutants, Amer. Chem. Soc., 605-609  (1978).
                                          395

-------
0.6 H.P. MOTOR
                    VANE AXIAL FAN
                                                                 HOLLOW  SHAFT MOTOR
                                                                           CHARGED
                                                                             FOG
                                                                    SPINNING
                                                                       CUP
                               FLOW STRAIGHTENER
             Figure 1.  Schematic of spinning cup fog thrower.

-------
•*c
Air In
Pleni
F*^"
3^ DiffuserV
\Cone ^-
let
im
& / /
^
Spinning Cup
Fog Thrower
HT3
V
A

Viewing
Port



Viewing
Port

/ / g
0 n
Particulate y / Axial
O O Sampling Hy Blade
C/M Sampling Ports 1 \ Fan
Port o \s
/ / 1
/ / / /
    Dust from
Vibrascrew Feeder

         I	.
10'
                                                               60'
                                   Figure 2.    Schematic of University of Arizona wind tunnel.

                                               (I foot = 0.30^8 meters)

-------
Heavy Dust Loading
 Ambient Relative
     Humidity
1
High
Charge/
Mass

1
Low
Charge/
Mass
 Light Dust Loading
 Ambient Relative
     Humidity
Figure 3.    Test plan.


         398

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                                                                                                          Meriam Laminar
                                                                                                          Flow Element
      Probe, Pitot Tube,
        Thermocouple
A
Horizontal
Elutriator
Sierra 5-Stage
Cascade Impactor
Silica Gel
  Trap
Control
 Valve
                                               Figure k.  Particulate sampling train.

-------
o
o
U.U13

1 0.010
m
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s 0.005
3
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-

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| Total Catch











Q Total - Probe Catch
















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                               Uncontrolled    Fog      High L/G;   Low L/G;    High L/G;  Low L/G;

                                            No Charge   High C/M   Low C/M    Low C/M  High C/M
                                     Figure 5.   Summary of test data — light dust loading.

                                                (1 gr/dscf = 2.2883 gm/dscm)

-------
    0.03
   0.025
   0.020

2  0.015

§
   0.010
   0.005
  0.000
I
                 |
           v
           y

         gp£
        U-U

                                      Sf>jc
                                                           u=U
                                                                       I Total Catch


                                                                       n Total - Probe Catch
                                                                        -2P
                                                                        I
                                                                 o
                   Figure 6.    Summary of test data — heavy dust loading.


                               (1 gr/dscf = 2.2883 gm/dscm)

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                   CONTROL METHODS FOR FUGITIVE AREA SOURCES
           Presented at the Fourth Symposium on Fugitive Emissions!
                            Measurement  and  Control
                                May  28-30, 1980
                   Monteleone Hotel, New Orleans, Louisiana
               Dennis J. Martin, Edward Brookman and Les Hirsch
                      TRC Environmental  Consultants,  Inc.

                              Dr. Dennis Drehmel
                     U.S.  Environmental Protection Agency
                                   ABSTRACT
    The prime control techniques for  fugitive  area  sources  are water sprays,
enclosures,  wind  screens  and  chemical   stabilizers.   A  review  of  the
literature  indicated  that while cost data was  readily available  for  these
methods, estimates of their efficiencies were  not supportable from the  given
data.   Nonetheless,  future work  on  wind  screens  and chemical  stabilizers
appears  warranted.   An  ongoing  field study  of a wind  screen  made  of  a
synthetic material indicates  that  efficiencies of over 60  percent should be
obtainable at a reasonable cost when applied to storage piles.
                                       402

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                              1.0  INTRODUCTION
    Due to  the  increased  regulatory  emphasis on  fugitive emissions,  interest
in  the type  and efficiency  of  controls  applicable  to sources  generating
these  emissions  has  been  steadily growing.  Prime among  the  sources of con-
cern are area sources, not  only because of the magnitude of  their emissions
but  also  since  they  are  not  amenable  to  types  of  controls  with  which
environmental engineers are most  familiar.  Furthermore,  data on  these types
of controls are  scarce and  scattered throughout  the  literature and,  to date,
there  has  not been  an attempt  to compare the various control options  on  a
cost effectiveness basis  to achieve  a priority ranking  for control  strategy
development.

    In order  to rectify  this situation the Particulate  Technology Branch of
EPA's  Industrial Environmental Research  Laboratory  (at Research  Triangle
Park)    is   sponsoring   a   program  being  conducted   by  TRC-Environmental
Consultants.  The purpose of the  program  is two-fold:   first,  a review of
the  literature  with respect   to  fugitive  controls  applicable   to  storage
piles,  unpaved  parking lots,  and disturbed  soil  surfaces  associated with
construction  activities;  and second,  presently  ongoing,  laboratory studies
on the more promising of  the  identified controls,  hopefully pointing the way
to future research.

    This  paper  presents  the results  of  the  completed  Phase I  effort and
discusses some of the preliminary findings of the Phase II projects.
                                       403

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                        2.0   PHASE  I  -  LITERATURE REVIEW

                          2.1   Techniques  Identified

     Methods,  identified from a literature search as prime control techniques
 for  fugitive  emissions  from  area sources,  were:

       o Water  Sprays.
       o Chemical  Stabilizers.
       o Enclosures.
       o Windscreens.

     Other  control  methods (e.g.,  tailings ponds, vegetative stabilizers, and
 housekeeping  procedures)  are not used  as extensively as the four cited above
 and  are not  dealt  with in   this paper  although  they will  be  covered in the
 final  report  to EPA.   Brief descriptions of  the  prime control  methods are
 given  below.

                               2.2   Water Sprays

     It  was  found that,  while a number  of chemicals have been  used  to reduce
 emissions  from  aggregate storage  piles and haul roads,  plain  water is still
 the  prime wetting agent  used.   Water use is  attractive  due to its relatively
 low  cost and  ease  of  application.   Effectiveness varies with amount applied,
 the  frequency of  application,  and  meteorological parameters  which  have  a
 direct  bearing  on  the  evaporation  rate of moisture.  Prom  the  latter point
 it can be  inferred  that the  spray  action itself  is  not  an  aspect  of  the
 control;  rather,  the use of water  to  increase  the apparent density  of  the
 dust  is the  control  mechanism.  Sprays  are  effective  only for very large
 particles  at  the  droplet sizes produced by  most  commercial  spraying  equip-
 ment.   Costs  vary  with  the  method  of application  (e.g., trucks,  spray bars)
 and  the amount  applied.  For large  storage piles,  the  cost of the  equipment
 alone can  be  high:   large watering  trucks cost  about $250,000.  Large  coal
 fields  which  require   continuous   watering   also  have  high  labor  costs
 associated with this  method  of control.   The  direct labor cost  of  watering
 one  50  acre coal field can exceed  $100,000 per year.

    Prom the  literature, a reasonable estimate of  the accuracy  of this tech-
nique  can  not  be  made  due  to the  conflicting  and  inaccurate data  found.
This point is discussed later.

    Disadvantages  to  using  water   as   a  control  for  area  sources  are  the
necessity  of   having  an adequate   water  supply  available,  the  need  for
 frequent reapplication,  and  the contribution  to the leachate amount.

                          2.3   Chemical Stabilizers

    Three  basic chemical  stabilizing   agents  are  used,  each  operating  to
different  principles:   wetting  agents,  hydroscopic   salts,   and   surface
crusting agents.
                                       404

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    Wetting agents have been used to  increase  the  effectiveness  of  water  and
some  of  the  chemical stabilizing  agents by  reducing  surface  tension  and
thereby enabling  the  water  (or chemicals)  to be spread  more  evenly and over
a greater surface area then before.  Disadvantages are the  same  as  those  for
water  alone,  with the  addition of  the leaching  of the  chemical  into  the
groundwater aquifer or water treatment system dealing with pile runoff.

    Hydroscopic salts, by attracting  the water out of the  air,  increase  the
surficial moisture content  of  the  dust, increasing  its  apparent density  and
thereby  reducing  its  emissions.  The prime  disadvantage to  the use  of such
materials  is  the  fact  that  they  are  water  soluble and  can therefore  be
easily washed  away.   A second  disadvantage  is that  the  salts (e.g.,  CaCl2)
are corrosive and may not be able to be used in all instances.

    Surface  crusting  agents,   third  type of  chemical  stabilizers,  can  be
composed  of  various  compounds?  e.g.,  styrene/butadiene  latices,  acrylic
latices,   vinyl   compounds,    synthetic  polymers,   lignosulfonates,   and
petroleum-based resins.  These  chemicals are  applied wet and  when  dry form a
hard  crust  on the  surface  of  the material  being  treated.   Costs  for  these
chemicals,  even  for   similar   types,   vary  widely   (see   Table  1).   Latex
compounds can  be  combined  with slack wax  and  filler materials (such as coal
dust)  which,  when applied at elevated  temperatures,  form a  waterproof
covering of  the  pile.  Costs for applying this  material are  reasonable (see
in Table  2  for various sized  piles).   Comparable costs  for  operations such
as compaction  and latex crusting  are shown in Table 3.   The direct savings
referred to occur from a reduction in  the  oxidation and water uptake of coal
and  are  on a  yearly  basis.  Total benefits  are based on  reductions in  the
cost  of treating  the  leachate  and  runoff of  the  pile, the elimination of the
need  to  monitor  the  pile's temperature, and other  related  functions.  Cost
benefits of hot melt  coatings  apply  only to degradable products such as coal
where waterproofing  the pile   yields  these  types  of results.  While these
compounds  have  never been tested  for effectiveness   it  is  reasonable  to
assume that  initial efficiencies approach 100 percent.  The  effective "life"
of these materials has not  been documented.

                                2.4  Enclosures

    Total  enclosures  should,  by definition, eliminate  wind-caused  fugitive
emissions  since the  wind would no longer come  into direct contact with the
source.   However, emissions still occur since ventilation of the enclosure
is  necessary  to  remove the  dust induced  by material  transfer operations.
These emissions  are  subject to normal  stationary  source control techniques,
however,  and  are effectively  controlled.   The  cost of this method can be
extremely  high  and  varies according  to  the size  and  type  of   structure,
associated  conveying  equipment,  etc.   Of  course,  small  piles  (e.g.,  sand
used   by  road  crews)   are  effectively  and  inexpensively controlled  by
weighted-down  tarpaulins.

                                2.5  Windscreen

    Windscreens  are  porous windbreaks  which reduce  the  velocity  of the  air
behind them.   Figure 1 illustrates  the  performance of  a  screen having  a
porosity of 50 percent.  Solid (zero porosity)  fences are not  used  as wind-
                                       405

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                                    TABLE  1

                           CHEMICAL  STABILIZER COSTS

Styrene/Butadiene Latices                     $25 to $50/103 Meter2

Acrylic Latices                               $50 to $160/103 Meter2

Vinyl Compounds                               $12 to $50/103 Meter2

Synthetic Polymerts                           $150 to $420/103 Meter

Lignosulfonates                               $25 to $50/103 Meter


                                    TABLE  2

                            HOT MELT COATING COSTS

 Pile Size
Metric Tons

 45,360

 90,720

226,800

453,600

680,400
Treatment

Compaction

Latex Crust
Surface Area
Meters
6,782
13,006
32,515
65,030
97,545

COST SUMMARY FOR
Cost to Treat
$/Metric Ton
Cost to Treat/ $
2,623
5,137
12,788
25,466
38,255
TABLE 3
MATERIALS APPLIED
Direct Savings
$/Metric Ton
Cost $/Metric Ton
0.058
0.057
0.057
0.057
0.057

TO COAL PILES*
Total Benefits — Value
Equivalent $/Metric Ton
0.088

0.126
Hot-Melt Coating   0.144
0.303

0.716

1.15
0.89

1.20

2.09
    * Assuming a coal pile of 250,000 metric tons at $20 per metric ton
                                      406

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     1QH       2QH        30H
     DISTANCE  IH FENCE HEIGHTS
 VERTICAL SECTION (ALONG £ 3F FENCE)
5QH
                                                     6QH
    DISTANCE IN FENCE HEIGHTS
          GROUND PLAN

FIGURE  1:  VJIND VELOCITY PATTERNS
                                                 4008-001
               407

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breaks  for  large  sources  since  the  downstream turbulence  created by  the
breaks  may  actually  induce  more  emissions  than  those which  would  have
occurred without the  breaks.  Figure  1 shows that a fugitive emission source
placed within  10 fence heights downstream of the  fence  would have  the  air
speed  reduced  to 40  percent  of  its  upstream value  in the  vicinity of  the
source.   (Note  that  this  does not mean  that the emissions would  be reduced
by  60  percent.)  The emission reduction depends  on the relationship between
the  air  speed  and  the amount  of particulate  matter  emitted and  has  been
estimated  to be anywhere from a straightforward  E   V1  to  E  V"9  and  just
about every  exponent  in between.   Also, note that, for every  type  of  dust,
there  is  a critical  threshold  velocity  at and below which  only  an insigni-
ficant  amount  of   particulate  matter  would  be   removed.   This  threshold
velocity  depends on  such  factors  as  particle  size,  adhesive forces  par-
ticular  to  the dust,  surface  moisture  content,   and  bulk density.   The
overall  efficiency  of  a  windscreen,  therefore,   depends  on  the  threshold
velocity of the dust, the  relationship between emission and  velocity and, of
course, local meteorological parameters.

    For example, suppose  that  50  percent of the  time the  wind  at  a  given
location  comes  from  a  30° sector and that a storage  pile  can  be  shielded
from  its  effect by  a semicircular fence.   Air   velocity readings  from  the
noted direction  can be broken down as:  -  10 percent of  the  time,  less  than
10  kilometers per hour;  60 percent of  the time,  10-20 kilometers  per  hour:
20  percent,  20-30   kilometers   per   hour  and   10  percent,  averaging   40
kilometers  per  hour.   If the  threshold velocity  of  the dust is  about 10
kilo-  meters per hour  and if  the  emissions are  proportional to  kv3  then,
before control, emissions can be described as:

    Emission rate   - k (0.6)  203 + ka(0.2)(30)3  +  k(0.1)(40)3

                    = k (4800 + 5400 + 6400)

                    = k 16,600

when the  highest value  of the velocity  range is  used  as  the average.  After
installing the fence, only  the  last  two ranges will be beyond the threshold
and the emission would be characterized as:

    Emission rate  = k (0.2) (15)3 + k (0.1) (20)3

                   - k (675 + 800)

                   = k 1475

There is a reduction  over  the uncontrolled wind  from the one sector of about
91 percent.  To determine the overall  efficiency  of the fence, the emissions
from the  unshielded  section of the piles  would  also have to be  determined.
If  these  emissions  were about  30 percent  of  the  total  (k   7115) ,  then  the
overall efficiency of the fence  would be  about   64 percent.   Naturally,  the
closer the  fence  is to the pile, and the  more  unidirectional the  wind  is,
then the greater is  the efficiency that can be achieved.

    Windscreens can  be made  of  various materials and can  be arranged in
various configurations.  Materials of  construction  include structural steel
                                      406

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wooden slats  in  a  cyclone fence, and a  synthetic  material of the  type  used
for glare  screens  and snow fences.   Cost varies with material,  design,  and
height.  A  movable 4  meter  high fence  could cost  about  $3,280 per  linear
meter  if made of structural  steel to enable  it to be picked  up  and moved by
forklifts.   A 25 meter high"permanent screen  could cost  the  same,  if made of
snow fence material.
                                       409

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                        3.0  COST-EFFECTIVENESS FACTOR
    The prime  end  result of the Phase I  literature  review was to  have  been
the  development of a  cost-effectiveness  factor  for  each  control  method
identified.

    In general,  although cost data were  relatively easy to obtain  from the
literature,  chemical manufacturers,  etc.,  efficiency  data  were,  for  all
practicable  purposes,  non-existent.   This is understandable for a  number of
reasons.    There  are  just  not  that  many reports  containing  hard  data  on
control efficiency  for  fugitive sources.   At  the beginning of the  study,  a
computerized  search  of  APTIC,  NTIS,   Engineering  Index,   and   Pollution
Abstracts yielded fewer  than  200  potential sources of information.  Most of
the publications examined did not contain  usable data.   Many articles  were
oriented  toward  control of fugitive  dust in  order  to  reduce nuisance  com-
plaints.   Typically  these reports described the  use of  a  type  of  control,
housekeeping procedure,  or combination thereof  which reduced the  incidence
of the complaints.   While these studies were useful  in showing the  state-of-
the-art control,  actual  data  test were,  for  the  most  part, not  given  or
available. •  In  the  relatively  few  instances where  control efficiency  data
were  obtained  or noted  in the publication, they  did  not meet  the  preset
criteria for acceptance.  These criteria were:

      o  Tests had to be  performed upon the  sources  using  acceptable method-
         ology and  instrumentation.

      o  Judgements  on  the  effectiveness  of  a  control under   different
         conditions than  those  tested were  not permitted unless strong  evi-
         dence of  a trend  was  noted  and  a  basis in theory established  for
         the phenomeon.

      o  Test data  and conclusions were  to be  considered absolutely valid
         only for the source  tested.  Extension  to similar sources  required
         that  those  factors   affecting   particle  transport   be  quantified
         during the  tests and  that data  on these  factors  be  available  for
         the similar  sources.   For example, particle size estimates would
         have  to  have  been made  for the  pile   tested  and  data  available
         indicating  that  the  size is  similar  for  similar  sources.  it  was
         not considered  necessary  that particle  size data be  available  on
         the  similar  sources   (although  this  would  have  been   the  ideal
         situation); rather,  engineering  judgement  could  be  used  to infer
         that the size  was the same.

      o  Data  from   tests performed  on   one type  of source  could  not  be
         extended to  dissimilar sources  (e.g.,   test results  on  sand   and
         gravel  operations  could  not  be  applied   to  coal  piles)  without
         extensive  supportive  evidence.
                                       410

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      o  Wind tunnel  testing  could  only  be  used  when  compared  with  field
         results or where various  control  options  were tested under  similar
         conditions.

    Applying these  criteria to  the publications  found  eliminated, for  all
practical purposes,  all of  the data  from consideration.   This  should  not
have  been  a surprise  for  a number  of  reasons.  As noted before,  available
data  are  not extensive.  Most  efficiencies of  available  data are  derived,
rather than  calculated  directly.   Also,  to confuse the  issue  somewhat,  some
numbers quoted  in the literature  appeared  to increase  each time  they  were
referenced.  As an example of how this can occur, one reference stated:

    "A study on the effect of  watering on construction  sites in-
    dicates  that  extensive   wetting  of  the  soil  may  reduce
    emissions from existing construction operations  up to  60 or  70
    percent.   The study  suggested  that  wetting  of  access  roads
    twice a  day with an application  of  .5  gal.  of  water  per square
    yard will  suppress dust emissions  from existing baseline con-
    struction practices by 50 percent."
The study cited actually stated:

    "Watering  on  construction  sites  produced a  wide  variation in
    apparent control  efficiencies, due  in  part to the highly vari-
    able  nature of  the emission  sources.   Activity  logs  kept at
    the construction  sites showed that some  sampling  periods with
    extensive  watering were  accompanied  by hi-vol  readings 60 to
    70  percent lower than  anticipated  with no watering,  while on
    other  days  the  apparent  effect  of   the  watering  was negli-
    gible.  The same variations were noted  in analyzing data from
    sampling  periods with  rainfall.  With daily  watering and com-
    plete  coverage,  average control  efficiency  is  about thirty
    percent.   This value  is partially  verified  by  another study
    indicating a  30 percent reduction  in  dust emissions over con-
    tinuously  traveled gravel  and dirt  roads on days  when their
    surface was moist.  However, with watering twice  a day at  the
    same  application  rate,  a  reduction  of  50 percent   appears
    feasible."

As can  be  seen,  these  studies did not  establish the effect of
watering,  but rather,  extrapolated   extremely  limited   data  to
produce undependable  results.

    In  conclusion,  evaluation  of the  literature  indicated  that
there is virtually no  accurate  or usable  data relating to control
efficiency  for fugitive  area sources and  that,  as  a result,  this
data  must be  generated.
                                       411

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                            4.0  PHASE II PROGRAMS
    The Phase  I  results indicated that  the  present state of  knowledge with
respect  to  fugitive  emission  generation and  transport  is not  extensive.
Available  information  on  control  technique  effectiveness  is  practically
nonexistent.   To alleviate  this  situation  somewhat,  Phase  II was  oriented
toward  a  better  understanding  of the  transport phenomena  and  a  first-cut
approach  to quantifying  the  effectiveness  of the  two most promising  tech-
niques,  chemical stabilizers  and  windscreens.   While  Phase  II  is  still
ongoing,  some  partial  results  are encouraging  and are  presented here  for
review.

                            4.1  Particle  Transport

    While much has  been  established  on  a  theoretical basis describing  the
behavior  of  particle  transport,  agreement  between  theory and  field  results
has been poor.   Part of the difficulty  lies  in the  oversimplification of the
approach  in  field studies  undertaken  to date.   For  example,   only  recently
has surficial  moisture  content  and the  size distribution of the  dust avail-
able for  transport been measured  during tests at storage  piles.   Attempting
to  force-fit data to  a  given  transport model  has  resulted   in  simplistic
equations good only  for the pile on which  the data were taken.   To  resolve
this, a wind tunnel study is being performed to quantify  the effects  of pile
shape,  moisture   content,  particle size,  and  turbulence intensity  on  the
quantity  of  emissions  generated.   To date,  only the  results  on pile  shape
are available.   These data  indicate that  the oncoming  wind  is  accelerated up
the slope of the pile  such that the air speed  at the top of the  pile is
increased  about  50  percent  over  ground  air  speed.   The  amount  of  the
increase  depends  somewhat  on  slope.    Slopes  with  leading  angles equal to
about  10° produce less than half  the   increase  in velocity  at  the top of
the pile  than  slopes  with  angles greater than 20°.  The high  velocities at
the top of  the pile  induce flow patterns as shown  in Figure 2.  While this
schematic is for  a  block, the same phenomenon holds  true for  a  pile with a
sloping edge.  Therefore,  in  predicting the emissions  from  a  pile,  the  air
speed used  in  a predictive equation may  not be  amenable to a  single value;
rather, emissions from  different  sections of the pile can be  referenced to
the  approach ground  speed only  if  different equations are  used for  each
section.  Ongoing work  in TRC's wind tunnel  will  be used to obtain the form
of these equations so that  future field  studies can use them to set up  their
testing programs and  evaluate their  results.

                            4.2  Windscreen Studies

    One of the more promising  control  alternatives  identified  in the liter-
ature  was windscreens.   A  major drawback  to their  use,  however,  is  the
materials of construction;  usually,  wood slats  in  a  cyclone  fence  or snow
fence  type  materials  are used.  While  such  materials  are acceptable  for
fences of limited height, protecting large  piles  could require fences  of 15
meters or more in height.   Long stretches of haul  roads,  while probably not


                                      412

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                     •s.




                     X.
V,  ^
                                   V,>V,>V3
                TOP VIEW
                  SIDE VIEW
       FIGURE 2:  FLOW PATTERNS ACROSS A BLOCK PILE
                                  4008-002
                     413

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needing a  high fence,  would  require  one  of sufficiently reasonable cost to
be applied to  long  stretches of road.  TRC's ongoing  investigation  includes
an evaluation  of a  synthetic  fence  material  manufactured  by  Julius  Koch,
Inc.,  of  New  Bedford,  Massachusetts.   Preliminary  results  indicate  that
performance of this material, available in  varying porosities,  is  equivalent
to those  of other  fence materials.   Since material  costs,  including  con-
necting hardware, are  approximately $19.7 per linear  meter  foe the 1  meter
wide  section tested, this material  is a preferred option in most  instances.
Ongoing studies  are  being performed  to evaluate the  use  of a  semicircular
and a circular fence.
                                      414

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                               5.0  CONCLUSIONS
    An evaluation  of the  available  literature  indicated  that  stated  effi-
ciencies  for  the  prime   control  techniques  applicable  to  fugitive  area
sources were based on unreliable data of  limited quantity.   For  this reason,
future testing  must be directed toward  developing this data.   Ongoing  wind
tunnel studies at TRC indicate that emissions  from a  storage pile depends on
pile  configuration  and that  seperate  equations  for different pile sections
may have to be developed to accommodate this phenomenon.

    Full-scale  field  testing  of a synthetic fiber windscreen indicates that
the screen  performs equivalently  to  other materials  and  that, due  to its
cost,  this  material  is preferable to  others.   Ongoing  programs  are  eval-
uating semicircular and circular screens.
                                       415

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                    CIVIL ENGINEERING FABRICS APPLIED
                    TO FUGITIVE DUST CONTROL PROBLEMS


                              Barry Levene
                  Air and Hazardous Materials  Division
                             EPA Region  VIII
                            Denver, Colorado


                            Dennis C.  Drehmel
                    Environmental  Protection  Agency
              Industrial  Environmental  Research  Laboratory
                Research  Triangle Park,  North Carolina
                                   ABSTRACT
      Fugitive dust sources contribute substantially to  both  total
 suspended particulate (TSP) and inhalable particulate.   Emission  rates
 from unpaved roads, construction activity,  and  other area  sources  have
 been estimated at 320 x 106, 27 x 106, and  4 x  106  tonsVyear,  respectively.
 This may be compared to 14 x 106 tons/year,  the emission rate  for  all
 point sources.  Within a given industry,  the contribution  of fugitive
 emissions can be more than 50% with the added problem that these  particles
 may contain toxic or hazardous substances.

      Civil  engineering fabrics are in common use for a  number  of  purposes
 including:   1) ground stabilization; 2) subsurface  drainage; 3) railroad
 construction and maintenance; 4) sediment control;  and  5)  erosion  control.
 Fabrics are available from Celanese, DuPont, Monsanto,  and Philips Fibers
 under the trade names of Typar, Bidim, Supac, and Mirafi.   Use of  these
 fabrics for air pollution control is a recent development  and  the  subject
 of recent and future field tests.

      Reduction of emissions from unpaved roads  is achieved by  covering  the
 road first with the fabric and then with coarse aggregate.  Unpaved
 parking lots, inactive piles, and construction  sites could be  controlled
 in the same way.  During tests in November 1979 on  an unpaved  road
 constructed with Bidim, the average reduction in TSP was 58% and  in
 inhalable particle concentrations was 46%.   More tests  are planned at
 both eastern and western sites in the spring of 1980 and a year-long
 monitoring at a western site will begin in the  summer of 1980.
*To convert tons to kilograms,  multiply by 907.
                                     416

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INTRODUCTION

     In the arid regions of the western United States,  local  sources  of
fugitive dust appear to be the most significant contributors  to ambient
levels of total  suspended particulate (TSP).   These sources also contribute
to the inhalable fraction although to a lesser degree.   Vehicles travelling
on unpaved roads are a major portion of these emissions, ranging from
54% of the total annual ISP emissions in Phoenix  to 9% in Denver and
48% in Colorado Springs.   An integral part of a particulate  control
plan is identifying fugitive emission control measures  for unpaved
roads.  In addition to unpaved roads, construction sites, haul  roads,
and open areas within industrial sites are important contributors to TSP
and may be sources of undesirable species such as lead.

     Traditional control techniques to reduce unpaved road emissions,
such as paving, chemical stabilizers, watering, gravel ing,gand traffic
controls, have been analyzed in several studies. * * '   ' '   However,
the use of a civil engineering fabric medium underlying the aggregate
roadbed is a promising new technique which, after further study, may
have application as an alternative control strategy in  the western
United States.  It may, in addition, have other benefits such as reduced
road maintenance.  Fabric under aggregate may also be used to control
unpaved parking lots, construction sites, and disturbed open areas.   For
these reasons, The Environmental Protection Agency (EPA) Regional Office
in Denver  is assisting  EPA's Industrial Environmental Research  Laboratory
at Research Triangle  Park in North Carolina  in  planning a study  of the
effectiveness of this  type of  road treatment on an unpaved road  segment
on the  Ft.  Carson Army  Base near Colorado Springs, Colorado. This paper
describes  the use of  civil engineering  fabrics  and their  role  in the
context of the  EPA particulate control  program.

BACKGROUND

      Even  with  the application of  Reasonably Available  Control  Technology
 (RACT)  on  all stationary  sources,  many TSP nonattainment  areas  are
 projected  to  exceed  the NAAQS  after  the Clean  Air Act's 1982 deadline.
 Control  of the  remaining  nontraditional  sources has  presented  a formidable
 planning  task  to  those responsible for State Implementation  Plans (SIP's).
 The  problem has been complicated by the lack of definitive information
 on the cost-effectiveness of the various  control  measures and  the like-
 lihood that a  new inhalable particulate standard is  in the offing.   Few
 States or local governments  are prepared to  commit large amounts of
 public funds to projects of uncertain value  in achieving the new
 inhalable particulate standards.  The Colorado Air Quality  Control
 Commission, in fact, has stated in policy paper 78-1 that it Is not
 reasonable to gear a control program to meet a questionable standard
 and that it is the policy of the Commission to direct  control efforts at
 the respirable fraction.

      The EPA Administrator recognized these problems in his February 24, 1978,
 guidance on SIP's for nonattainment areas.  This guidance states that after
 RACT for traditional sources, States could conduct demonstration projects
 and studies in lieu of adopted specific measures as long as the data on


                                       417

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costs and benefits could be analyzed and  strategies adopted and  implemented
in time to meet the 1982 deadline.

     As SIP's were submitted in the months  following  January  1,  1979,  it
became apparent that most states had opted  for the demonstration project
alternative, although a few areas,  such as  Phoenix and  Colorado  Springs,
committed to extensive paving programs, which  have since  been delayed.

     As a result EPA has provided further guidance on what should be the
emphasis areas in 1980 while the standards  review  is  in progress.  The
first priority is to assure that RACT is  applied to all traditional sources.
The second is for those areas which have  not yet done so  to complete a
problem assessment of sources, emission,  and nature of  particulate  (size
distribution in particular).  EPA will  be supporting  several  major studies
of available control measures to determine  source/receptor relationships,
effectiveness, and air quality impacts.

     EPA's Denver Regional  Office has supported many  such studies which
may eventually lead to widespread implementation.  Through a  grant to  the
State of Colorado, a study design is now  being developed  to conduct an
evaluation of alternative snow control  practices.  The  demonstration study
of civil engineering fabric in unpaved  roads fits  in  well with  EPA guidance
by providing an ideal opportunity to evaluate  promising new technology.

FABRIC DESCRIPTION

     At least four major manufacturers  of civil engineering fabrics market
in the United States.  These companies  are  Celanese,  duPont,  Monsanto, and
Philips Fibers.  A description of some  of their products  is shown in Table  1.
Most manufacturers offer a  range of properties according  to thickness.
Data in Table 1 should be interpreted as  showing  that generally the same
range of properties is covered by all manufacturers.  Usually civil engineer-
ing fabrics are sold for road stabilization, support, drainage,  erosion
control or reinforcement.  Such fabrics have been  used  under  railroad
tracks, rip-rap, and paved and unpaved  roads.   Fabrics  are available in
strengths to take loads from haul trucks  and railroad trains, are rot
resistant, and have been estimated to have  a useful lifetime  of 12 years.
The approximate 1980 cost is $1.00 per  square  yard.

FIELD TEST SITE DESCRIPTION

     The test section is a  610 meter (2,000 foot)  segment of  unpaved road
located at the northern boundary of the Ft. Carson military installation
south of Colorado Springs,  Colorado.  There were  several  reasons for the
selection of Ft. Carson as  the site.  First, Ft. Carson officials were
interested in cooperating in such an experiment.   As  a  training center
for ground-based artillery, the base contains  long stretches  of unpaved
roads and cleared areas which are subject to fugitive dust emissions.
For sometime Ft. Carson has been considering conducting experiments with
various dust palliatives to reduce these  emissions.   Ft.  Carson officials
were most cooperative in assisting in site  selection, providing monitoring
equipment, and installing the fabric itself.  In addition, the  fabric
                                    418

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VC
                              Table 1.  PROPERTIES OF CIVIL ENGINEERING  FABRICS

                                                          Brand Name
Composition
Structure
Thickness, mils
Weight, oz/yd2
Grab Strength, Ib
Burst Strength, psi
Water Permeability,
Bidim
polyester
spunbonded
60-190
—
115-610
225-850
0.03
Mirafi
polypropylene
woven
25
4
200
325
-__
Supac
polypropylene
heat bonded
50
5.3 (up to 16)
150
(cross direction)
300
0.05
                                                                                       Typar

                                                                                       polypropylene

                                                                                       spunbonded

                                                                                       15

                                                                                       4

                                                                                       130
              cm/sec
                                        To  convert to metric equivalents

                                      Multiply         by_           to convert to
                                     mils  ,
                                     oz/yd'
                                     Ib
                                     psi
0.00254
25.9
453.6
703.1
cm ?
9/m
gram,,
kg/nT

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had not yet been tested at a western site.

     The road extends in an approximate north-south  direction and  provides
access to several  residential  areas  on  the  post.   It is  not  in the training
area, but is used mainly by Army personnel  in light-duty vehicles  enroute
from or to these residences.  An occasional  track  vehicle uses the road
as well.  Open fields extending for  100 meters or  more lie on both sides
of the road.  The test section slopes gently upward  toward the south  end.
The majority of the traffic traverses the entire length  of the segment, but
an occasional vehicle either enters  or  exits at two  infrequently used
intersections.

     In November 1979, a Monsanto fabric was installed in the southernmost
305 meter (1,000 foot) section by Ft. Carson construction crews under
Monsanto supervision.  The northern  section is being used as a control
section.

TEST RESULTS

     Field tests of ambient particulate concentrations around the  test
road were conducted in November 1979 and April 1980. The test apparatus
consisted of upwind and downwind stations equipped with  Hi-Vols and
dichotomous samplers in November and Hi-Vols and size selective Hi-Vols
in April.  The data derived from the Hi-Vol  measurements are shown in
Table 2.  The lower increase in ambient concentration downwind of  the
fabric-plus-aggregate road is shown  by comparison  to the increase  across
the control section.  The fabric-plus-aggregate road gave an average  of
47% lower emissions within a range of 30 to 70% lower emissions.   Wind
speeds during November were lower than  during April  which corresponded
to greater emissions reductions during November than during  April.

     Data for the control of inhalable  particles  (those  with diameters
less than 15 micrometers) are shown  in  Table 3. As  noted above, the
November data was derived from dichotomous  sampler measurements and the
April data from size selective Hi-Vol measurements.   The percentage
reduction shown in the table is again the lower increase in  emissions
from the fabric/aggregate road as compared  to the  control road.  The
reduction averaged 43% within a range of 26 to 53%.   Again the reduction
was slightly greater with lower wind speeds.

     These results may be used to compare the cost effectiveness of civil
engineering fabrics for unpaved road control to other methods as shown
in Table 4.  Based on cost estimates by Cooper9 and  Blackwood.10 the
other methods have a cost of at least $220  to $300 for each  kilometer
of road per year per % reduction in  emissions.  For  fabric/aggregate
roads, the cost is $140 per km/yr/%  reduction.  Thus, the fabric/aggregate
road is more cost-effective and avoids the  problem of availability of
water in arid regions for watering or that  of oil  runoff for oiling.

FUTURE MONITORING PLAN

     The current plan calls for a 1-year study to  collect data on  the
following parameters:  total suspended particulate,  size fraction  under 15
micrometers, vehicle counts, precipitation, and wind speed/direction.

                                    420

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          Table 2.   CONTROL EFFICIENCY OF ROAD CARPET (BIDIM)
                         FOR TOTAL SUSPENDED PARTICLES
Date                      Wind Speed, mph               % Reduction

11/7/79                        0.6                          60

11/9/79                        2.4                          59

11/14/79                       0.3                          30

11/16/79                       0.2                          70

4/28/80                        7                            35

4/28/80                        7                            44

4/29/80                        8                            36

4/29/80                        9                            39


Average                                                     47
 To convert mph to  cm/sec  multiply by 44.7.
                               421

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        Table 3.   CONTROL EFFICIENCY OF ROAD CARPET  (BIDIM)
                        FOR INHALABLE PARTICLES
Date                       Mind Speed,  mph            % Reduction
11/7/79                         0.6                       53
11/9/79                         2.4                       31
11/13/79                        1.5                       49
11/16/79                        0.2                       48
4/28/80                         7                         45
4/28/80                         7                         39
4/29/80                         8                         26
4/29/80                         9                         49

Average                                                   43
To convert mph to cm/sec multiply by 44.7
                              422

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Table 4.  COSTS OF UNPAVED ROAD CONTROL
  Expected
Cost Effectiveness
Method
Oiling
Watering
CaCl2
Road Carpet
Efficiency, %
50-98
40
60
45
by Cooper"
up to 180,000
25,000-39,000
18,000
—
by Blackwood1"
11,000
11,500
—
6,000
$km-yr-%
220-1800
290-1000
300
140

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Five pairs of Hi-Vols/Hi-Vol with size selective inlets are to be used.
Because the predominant winds are drainage winds which are diurnal in
nature, from the northwest in the morning and southeast in the afternoon,
the monitor pairs are located north of the center point of each test
section and should measure mainly upslope afternoon emissions.  A background
site will  be located far enough away so as not to be impacted by road
emissions.

     Instruments will be maintained and filters weighed by the local
health department which conducts the TSP monitoring for the State and is
cognizant of EPA quality assurance procedures.  Samples will  be taken
every 6 days to correspond to the sampling schedule for other Hi-Vols in
the area.   Because of the heavy filter loadings, 4 or 8 hour samples may
be taken instead of the normal 24-hour sample.

     All data collected will be submitted to the EPA Regional Office for
analysis and publication of results.

     Data collection should begin in June or July and continue for 1
year. A preliminary report should be available, based on 6 months of
data, by April  1981, and a final report should be available late in
1981.

REFERENCES

     1.   "An Implementation Plan for Suspended Particulate Matter in
the Phoenix Area, Vol.  II, Emission Inventory,"  TRW, Inc., June 1977,
EPA-450/3-77-021b (NTIS PB 278178).

     2.   Colorado State Implementation Plan, as submitted to EPA in
January 1979.

     3.   "An Implementation Plan for Suspended Particulate Matter in
the Phoenix Area, Vol.  IV, Control Strategy Formulation," TRW, Inc.,
June 1977, EPA-450/3-77-021d.

     4.   Blackwood, T. R. and R. A. Wachter.  Source Assessment:  Coal
Storage Piles.   Prepared by Monsanto Research Corporation for the Industrial
Environmental Research Laboratory, U. S. Environmental Protection Agency,
Cincinnati, Ohio, May 1975.

     5.   Chalekode, P.K., T. R. Blackwood, and S. R. Archer.  Source
Assessment:  Crushed Limestone, State-of-the-Art.  Prepared by Monsanto
Research Corporation for the Industrial Environmental Research Laboratory,
U. S. Environmental Protection Agency, Cincinnati, Ohio, April 1978.

     6.   Metzger, C. L., Dust Suppression and Drilling with Foaming
Agents. Pit and Quarry Magazine.  March 1976.

     7.   Harwood, C. F., and P. K. Ase.  Field Testing of Emission
Controls for Asbestos Manufacturing Waste Piles.  Illinois Institute of
Technology Research Institute, May 1977, EPA-600/2-77-098 (NTIS PB
270081). May 1977.
                                      424

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     8.   Kromrey,  R.  V.,  R.  Naismith,  R.  S.  Scheffee,  and R.  S.  Valentine.
"Development of coatings  to reduce fugitive emissions  from coal  stockpiles."
In Third Symposium  on  Fugitive Emissions Measurement and Control.   EPA-
600/7-79-182 (NTIS  PB  80-130891).

     9.   Cooper, D. W.,  J. S. Sullivan, M. Quinn, R.  C. Antonelli, and
M. Schneider.  Setting Priorities  for Control of Fugitive Particulate
Emissions from Open Sources.   Harvard University School of Public Health,
August 1979, EPA-600/7-79-186 (NTIS PB 80-108962).

    10.   Blackwood, T. R. Assessment of Road Carpet for Control  of
Fugitive Emissions from Unpaved Roads.  Monsanto Research Corporation,
May 1979, EPA-600/7-79-115 (NTIS PB 298874).600/7-79-115.  May 1979.
                                      425

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                   FUGITIVE  PARTICLE EMISSION  CONTROL  USING
                     SPRAY CHARGING AND  TRAPPING  SCRUBBER

                              Dennis C. Drehmel

                    U.S. Environmental  Protection Agency

                Industrial  Environmental Research Laboratory

                Research Triangle Park, North Carolina  27711



     Shui-Chow Yung, Richard Parker,  Sudarshan Bhutra, and Seymour Calvert

                       Air  Pollution Technology, Inc.

                        San Diego,  California  92117



                                   Abstract


     The control of fugitive process emissions (FPEs) with a Spray Charging and
Trapping (SCAT)  scrubber was evaluated both theoretically  and experimentally.
The SCAT system uses an air curtain  and/or jets  to contain, convey, and divert
the  FPEs into a charged spray scrubber.
                                           3
     Experiments were performed on an 3.8  m /s bench-scale spray scrubber
to verify the theory and feasibility of collecting  fugitive particles  with
charged water spray.  The effects of charge levels  on  drops and particles,
nozzle type, drop size, gas  velocity, and  liquid/gas ratio on collection
efficiency were determined experimentally.   The  results  of the experiments
and the comparison between theory and data  are presented.

     An air curtain was developed for conveying  the FPEs to the spray
scrubber, deflecting the crosswind, and containing  hot buoyant plume.
The design and air flow field for the air  curtain are  presented.

     The SCAT system is also being applied  to improve  the  capability of
street sweepers for collecting inhalable particles.  Preliminary design
approaches are presented.
                                      42G

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                  FUGITIVE PARTICLE EMISSION CONTROL USING
                    SPRAY CHARGING AND TRAPPING SCRUBBER
Introduction

     Fugitive emissions constitute  a  large percentage  of total  particulate
emissions.   Therefore,  control  of fugitive process emissions  and  fugitive
dust will be an essential  ingredient  in  control  strategies for particles.
EPA classified fugitive emissions into two categories:  fugitive  dust
emissions and fugitive  process  emissions.   Fugitive dust emissions originate
from non-industrial activities; e.g., wind blown dust, entrained street dust,
agriculture, and construction and demolition.   Fugitive process emissions
are any non-ducted emissions due to industrial activities such as loading
and unloading raw materials, unpaved  road in a plant,  metal pouring, and
material charging.

     Fugitive emissions are diffuse and typically come from many small
sources as opposed to a single large emitter.  Present control methods use
 secondary  hooding  at the  local  source of  emissions, total  building
enclosure  and evacuation, or water sprays.  Secondary hooding and total
building enclosure and evacuation require high energy and capital invest-
ments.   In addition, secondary hooding may not be efficient  in gathering
fugitive  emissions.

     Spraying with water  could be effective for some  processes and  materials
which  can  tolerate water, such as transfer of raw materials  on conveyor
 belts.   The  main function of the spray  in this application is  to stabilize
 the dust to  keep it from  dispersing.  If  the  dusts  are  already airborne,
 spraying with water alone will  not do much good.  The water  drops can catch
 some particles.  However, the drops  and collected particles  will re-disperse
 in the air after the water  has  evaporated.

     A much simpler and  cheaper method  for  controlling  fugitive  process
 emissions  is by diverting the  fugitive  particle emission (FPE) into a
 control device located near the source.   The  particles  are then  removed
 for the air and disposed of.   The  SCAT  (Spray  Charging and Trapping)
 scrubber  is  such  a  system.    It uses air curtains  and/or jets to
 contain, convey,  and divert the FPEs into a charged spray scrubber.  This
 control method minimizes the apparatus  required to contain,  convey, and
 control the fugitive emissions.

 SCAT System

      Figure 1 shows an example of  the SCAT system.  It  has two sections.
 One section contains the air curtain and air push jet assembly.  The  other
 section consists of a  particle control  device.   The SCAT system uses  water
 sprays, which could be charged for particle removal.

      The  two sections  are arranged in a  push/pull arrangement with the
 fugitive  particle emission source situated between the two  sections.
 The fugitive particles are contained with air curtains  and  are  pushed away
                                      427

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from the source into the spray scrubber.   The scrubber has a low pressure
drop entrainment separator (e.g.,  zigzag baffles) to remove the spray drops.

     The water from the entrainment separator can be 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.  Alternatively,  a blow-
down stream of dirty liquid may be directed to a disposal  system.

     The major SCAT system feature which suits it to FPE control is the use of
air curtains and/or air push jets to contain and convey FPEs.   The use of
air curtains will minimize the requirement of solid enclosure (hooding).   It
will be easy to build and unobstrusive.   The air curtains  could also be used
to deflect the wind to minimize the dispersion and the volume of air to be
cleaned and be used to contain FPEs from  hot sources.   For example, the
Naoshima Smelter of Mitsubishi Metal Corporation at Naoshima Island uses
a system similar to SCAT to control the fugitive emissions from a
copper converter (Uchida, et al.  1979).   In that system, fumes from the
converter are contained and then  are ducted to a central particle control
device.

     A SCAT system could have the following components.

     1.  Air curtain and/or air push jets,
     2.  Water sprays (could be charged),
     3.  Entrainment separator,
     4.  Fan and pump, and
     5.  Water treatment.

     It is not necessary for a SCAT system to have all  the components.   There
is no one fixed design and configuration.  Its design depends on specific
sites and applications.  Of the above five components,  air curtains and water
sprays required further study.  To generate design information quickly, the
air curtain and the spray scrubber were studied individually in separate
bench scale devices before being  combined into one prototype SCAT unit.  The
prototype was then used to determine the  effect of crosswind, hot source,
and particle containment efficiency.

Air Curtain Study

     An air curtain is a sheet of air blown either by a jet or out of a slot
at high speed.  It has been widely used in industrial  and commercial plants,
mainly to provide constant access or to isolate a warm interior from the
cold outdoors or vice versa.

    Most  of the published information on air curtain performance and design
has been related to air conditioning and  ventilation.   There is little
published literature on its dust containment capability even though it has
been used for this purpose in  industry.  Only one report has been published
on the application of air curtains to block or deflect  crosswinds.

     Design of the SCAT system requires information on  several parameters of
the air curtain jet stream such as the jet expansion  angle, air entrainment


                                     423

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ratio, mixing  of  particles  in the curtain, effect of crosswind, and the
effect of hot sources.   The  jet  expansion angle and  particle mixing  deter-
mine the overall  cross-sectional dimensions of the  spray scrubber  or the
receiving hood.  The air entrainment ratio determines  the volumetric
flowrate.  The crosswind and heat effect dictate the placement of  air
curtains and the sprays.  These  parameters are being studied.

     In the SCAT system, the air curtain should have a small expansion
angle, small air entrainment ratio,  and a uniform velocity distribution.
It is generally known that for uniform velocity distribution the distri-
bution manifold or duct should have a constant static pressure from end
to end.  To obtain constant static pressure, the manifold should have
either a very  large cross-sectional  area compared to the total nozzle
area or a decreasing cross-sectional area to keep the velocity head in the
manifold constant.

     Early  attempts to  simplify construction of an air curtain manifold
by drilling holes along the duct did not yield uniform flow.  The main
reason was  that the duct  cross-sectional  area  was not much  larger than the
total hole  area.  A better  distribution manifold shown in Figure 2 was
built.  The manifold was  of rectangular cross-section 35.6  cm x 30.5  cm.
An adjustable  plate was placed  in the duct so  that  the flow area decreased
along with  duct.  Ideally the plate  should be  curvilinear in shape.   But
for  the  short  duct  used in  the  present  study, about  3 m  in  length,  the plate
may  be  straight.  The  use of  straight  plate  greatly simplified  the
 construction.

      The air  jet  nozzle was a continuous  slot 2.1 m (7  ft)  long.  The slot
was  formed by two parallel  plates which protrude 22.9 cm (9 in.)  from one
 side of the duct.   The distance between the  plates, which is the  slot
width,  could be  adjusted.  The  slot was divided by thin cross-plates,
 7.6  cm (3 in.) apart,  so  that the  air  would  discharge perpendicularly to
 the longitudinal  axis  of  the  duct.

      Velocity profile  was measured with the slot oriented vertically.
 Linear velocity was measured with a hot wire anemometer for three vertical
 levels at three downstream  locations from the slot.  Figure 3 shows the
 measured velocity profile.   As  can be seen the velocity distributions for
 the three vertical  levels are virtually identical.   Therefore, the air
 curtain flow field is  uniform.

      The air curtain flow field was measured for several slot widths and
 air slot exit velocities.  The results were compared with  the equations
 suggested by McElroy  (1943) for a two-dimensional jet exhausting into still
 surroundings  and jets with two-sided expansion.

      Figures  4 and 5  show  the measured center!ine axial velocity decay
 and entrainment ratio, respectively.  The agreement between the measured
 and predicted centerline velocity decay  is  good.  The measured entrainment
 ratio was  lower than  that  calculated.
                                      429

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     The lower measured entrainment ratio could be due to a  smaller inclu-
sive jet expansion angle.   The measured jet expansion angle  varied between
20° and 28°, depending on  air exit velocity.   This is smaller than that
reported by Tuve and Priester (1944) of 32 - 34° and that suggested by
Hemeon (1963) of 30 - 40°.

     The jet expansion angle and entrainment ratio were also measured for
the first air curtain manifold (duct with drilled holes) we  had tested.
The jet expansion angle was 35°, which was close to Tuve and Priester
results and within the range recommended by Hemeon.  The measured entrain-
ment ratio for this air curtain agrees with that calculated  from theory.


Charged Spray Scrubber Study

     Bench scale experiments were performed to determine the minimum water
requirements, to aid the selection of spray nozzles, to study various
drop charging  methods to  determine the  effect of drop and/or particle
charging on particle collection efficiency, and to verify published
theories.

     Figure 6 shows a sketch of the charged spray scrubber system.  In
order to enable us to make good measurements, it is much more elaborate
than the actual SCAT will  be.

     The system was made in sections jointed by flanges.  The scrubber was
made of thin aluminum sheets and supported on PVC frames in  order to
permit electrical current  measurements.   The cross-section of the scrubber
is 0.91 m x 0.91 m (3 ft x 3 ft).  The overall length, including the
blower, is about 11 m (36  ft).

     The scrubber system consists of a flow straightening section, an
inlet particle sampling section, a particle charging section, a spray
section, an entrainment separator, and an outlet sampling section.  It
should be noted that all sections except the spray and entrainment
separator section will not be included in an industrial installable
SCAT system.  The inclusion of the sections in the bench scale device is
for the purpose of studying various combinations of components and to
provide for good particle  sampling and electrical measurement.

     The particle charging  section  consisted  of two rows of  corona wires.
Wire diameter was 0.18 mm  (0.007 in.).  The spacing between  wires within
the same row was 6.5 cm (2.5 in.).  The ground electrodes were 1.3 cm
(0.5 in.) diameter aluminum tubing.

     The overall length of the spray section was 2.44 m (8 ft) including
two spray banks.  The water was charged by induction.   The nozzles and
water feed lines were kept at ground potential.  A high voltage grid
assembly was placed in front of the nozzles to charge the water drops.
This arrangement not only  simplified  construction,  by eliminating a
complicated electrical isolation system,  but also  gave  a  high charge  level
on drops.
                                     430

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     The scrubber was  operated for four conditions:

     1.   Uncharged  particles/neutral  drops,
     2.   Charged  particles/neutral drops,
     3.   Uncharged  particles/charged  drops,  and
     4.   Charged  particles/charged drops.

     Figures 7 and  8 show the data for nozzles  "A"  and "B",  respectively.
The measured mass median drop diameter, spray angle,  and discharge
coefficient for nozzle "A" (hook type) was 240 ym,  100°, and 0.63,
respectively.  Only one spray bank was used in all  experiments and nozzle
pressure was maintained at 432 kPa  (48 psig).  One power supply was used
to charge both the  particles and the  drops.   The applied voltage was
-10 kVDC.  The measured charge/mass  ratio was +5.8 x  10~5 C/g and -1.5
x 10"5 C/g for drops and particles,  respectively.

     As can be seen from Figures 7  and 8  the collection efficiency of the
spray scrubber improves by charging  either the water or the particles.
Further improvement was measured when the water and particles were
oppositely charged.  The improvement is more with submicron particles.
For particles with diameters larger than 5 ymA, charging the water and/or
particles  has little effect on efficiency.

     The scrubber with nozzle "A" has better collection efficiency at a
lower liquid/gas ratio than that with nozzle "B".  A  possible reason  is
that nozzle  "A"  produced finer drops.

Comparison  Between  Data and Theory

     The model by  Calvert (1970, 1975) along with the drop trajectory
formula given by Giffen and  Murozew  (in Walton  and Woolcock,  1960)  and  the
appropriate single drop collection efficiency were used to  predict the
spray  scrubber performance.   Figure  9-shows  the predicted and the measured
grade  penetration  for the uncharged  particle/neutral  drop condition.
As can  be  seen,  the agreement is good.

      For electrostatically augmented conditions, i.e. either one or
 both of particle and drops were charged,  Nielsen's  (1974) graph for single
 drop collection  efficiency was  used  in the calculation.  The results were
 identical  to that  for the uncharged  condition.   This means  there should
 be no improvement  in efficiency with electrostatic augmentation.  This is
 contrary to experimental  findings.   The  discrepancy  could be due to the
 assumption that  drops were of uniform size and carried the same amount of
 charge.

      Collection  in a  vertical direction was  not included  in the calculations,
 While collection in a  vertical  direction  is  negligible for  the uncharged
 particle/uncharged drop condition,  it could contribute to  particle
 collection for the  charged  system due to the  low  relative  velocity between
 the  drops  and the particles.
                                     431

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Prototype SCAT Scrubber

     A prototype SCAT system was designed and built based on the
information generated in air curtain and spray scrubber studies.   Its
configuration is similar to that shown in Figure 1.   It had two separate
sections.  One section housed the charged spray scrubber;  the other section
had three air curtains and one air push jet.   Both sections were mounted on
casters; therefore, the distance between the  air curtains  and the spray
scrubber could be adjusted.

     The charged spray scrubber had a cross-section  of 2.44 m x 1.83 m
(8 ft x 6 ft).  The bottom 0.61 m (2 ft) was  the scrubber  sump.  There-
fore, the active scrubber was made of aluminum plates.


     There were 36 pigtail type spray nozzles at the scrubber front surface.
The sprays are cocurrent with the gas flow.   The capacity  of each spray
nozzle is 9.8 £/nrin (2.6 6PM) at a nozzle pressure of 377  kPa (40 psig).
The nozzle discharge coefficient is 0.6 and  the drop diameter is 200-250 urn.

     About 1  m downstream from the sprays were four  rows of zigzag baffles
to remove the water drops.  There was a blower at the scrubber outlet.  The
blower is rated at 963 m3/min  at 2.5 cm W.C. pressure drop  (34,000  CFM
at 1  in. W.C.).

     The other section had three independent  air curtains  and a propeller
fan.   Two of the air curtains were mounted vertically and  about 1.83 m
(6 ft) apart.  The other  curtain was mounted horizontally 2.7 m  (9  ft)
above the ground.   The air curtains could be  swivelled as needed  to deflect
crosswinds and contain buoyant smoke plumes.   The propeller fan was located
at the center.  The fan was for producing a  "push" jet.

     The prototype SCAT system was used in crosswind, hot source, and
containment  efficiency measurements.

Hot Source Experiments

     We are conducting experiments on the prototype  SCAT system operating on a
simulated FPE hot source.   Figure 10 illustrates the test  setup.  A
furnace is used to generate a hot buoyant plume.  Smoke is injected in the
plume as a tracer.  We will monitor the air  curtain  angle, flow rate,  and
slot geometry required to divert the hot plume into  the scrubber.  No  data
are yet  available.

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Application of SCAT Scrubbing  on  Street Sweepers


     As an application of the  SCAT approach,  Air  Pollution Technology,  Inc.
(A.P.T.) has undertaken a program to develop  a special  purpose street sweeper.
At present street sweepers are not designed to collect inhalable particles
dispersed during street cleaning.

     The objective of the study is to retrofit existing vacuum sweepers
with an air pollution control  system to collect 90 percent of the inhalable
particles dispersed by the sweeper.

     The study is divided into two phases.  Phase I includes a theoretical
and experimental study to define and verify estimates of power and water
requirements as well as cost and performance of the add-on system.  In
Phase  II a conventional vacuum sweeper will be modified and evaluated
under  various street conditions.

     A.P.T. will modify a regenerative air type vacuum sweeper to collect
inhalable particles dispersed during street sweeping.  A  schematic diagram
of the sweeper operation  is given  in Figure 11.  The gutterbroom  transfers
the dirt from the  curb to the pick-up  head.  Air flow  in  the  pick-up
head conveys  the dirt  to  the  hopper where  the coarse particles are removed.
The air is  then  recirculated  to  the pick-up  head.  The two sources of  fine
dust dispersion  are  the  gutterbroom and  the  pick-up  head.   Dust  dispersed
by the gutterbroom will  be conveyed to the spray  scrubber and collected.
Further,  a  stream  of  air will be exhausted from  the  system to ensure a
positive intake  of air at the pick-up  head.   This  will reduce air "spills"
created by  the  air in the head.   Inhalable particles will  be  removed from
the  air stream  before exhausting it into the atmosphere.   Fine water sprays
will  be used  to  collect and agglomerate suspended dust particles.   Either
the  drops or  the particles  (or  both) may be  electrostatically charged to
increase the  particle collection efficiency.   The dust collection system
will  consist  of a  charger and water sprays followed  by an entrainment
 separator.

      The primary design constraints for this system  are:

      1.  Minimize water usage,
      2.  Maximize collection  efficiency for inhalable particles through
          electrostatic augmentation,
      3.  Optimize entrainment separator to collect drops and coarse
          particles, and
      4.  Minimize power required  for air recirculation.
                                      43J

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Conclusions

     The SCAT system is a simple, versatile and effective technique for controlling
fugitive emissions.   It involves the use of air curtains and air jets to
contain and convey the emissions into a nearby spray scrubber.


     The collection efficiency  of a  single spray bank scrubber was
 investigated experimentally.  The collection efficiency could be improved
 by charging  the water  and/or the particles.  The measured particle
 penetration  agrees with  theoretical  predictions.  For charged water  and/or
 charged particle  condition, the measured penetration is lower than the
 predicted.

     Air curtains have been used in  industries to contain dust but no
 carefully  performed study has been reported in the  literature.  The  air
 curtain developed in the present study  can achieve  a smaller expansion
 angle  and  a  lower entrainment ratio  than those  reported in  the  literature.
 Small  expansion angle  and entrainment ratio are  beneficial  to the  control
 of fugitive  process emissions with the  SCAT system.

     A prototype  SCAT system has been built by A.P.T.  to study the  effects  of
 crosswind, hot buoyant plume, and containment efficiency.  Experiments are
 currently  underway.

     The SCAT concept  is also being  applied to urban street sweepers to
 improve their effectiveness in  controlling emissions of  inhalable particles
 from paved streets.  Preliminary analysis indicates that the system  is
 very promising and can have a significant impact on urban air quality.
                                    434

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                                REFERENCES
Calvert, S.  Venturi and Other Atomizing Scrubbers,  Efficiency and Pressure
Drop.  AIChE J.  16.:   392-396,  1970.

Calvert, S., et al.  Study of Flux Force/Condensation Scrubbing of Fine
Particles.    EPA-600/2-75-018  (NTIS PB 249297), August, 1975.

Hemeon, W.C.L.   Plant and Process Ventilation. Second Edition.  The
Industrial  Press,  New York,  1963.

McElroy, G.E.  Air Flow at Discharge  of Fan-Pipe Lines in Mines.   Part II.
U.S. Bureau of Mines Report  of Investigation 3730, November 1943.

Nielsen, K.A.  Effect of Electrical  Forces on Target Efficiencies  for
Spheres.  Eng.  Research Inst.  Tech.  Report 74127, Iowa State Univ., 1974.

Tuve, G.L.  and G.  B. Priester.  Control  of Air-Streams in Large Spaces.
Heating, Piping and Air Cond., ASHVE  Journal, January 1944.

Uchida, H., et al.  Processing of Copper Smelting Gases at Naoshima
Smelter.  Paper presented at the Control of Particulate Emissions  in the
Primary Nonferrous Metals Industries  Symposium.  Monterey, California,
March 1979.

Walton, W.H. and A.  Woolcock.   Aerodynamic Capture of Particles.   E.G.
Richardson, editor.   Pergamon Press,  Oxford, England, 1960.
                                    435

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          AIR
          CURTAIN
PUSH FAN
   OR
PUSH JET
          AIR
          CURTAIN
SPRAY
SCRUBBER
                              PULL
                              FAN
ENTRAPMENT
SEPARATOR
          Figure 1.  Example of SCAT system arrangement.

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                     AIR  IN
    210 cm
Figure 2.   Air curtain  distribution duct.
                    437

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Ul
,
i )
f. <
to
• ;
     0
        DISTANCE DOWNSTREAM FROM SLOT = 4.6 m
DISTANCE DOWNSTREAM
FROM SLOT = 3.1  m
   .
        DISTANCE DOWNSTREAM
       . FROM SLOT =  1.53 m
     0 *
                                       I SLOT GAS  EXIT VELOCITY  =  23 m/s
                                        SLOT WIDTH  = 1.3  cm
                                       \ SLOT LENGTH = 183 cm
        O MEASURED AT  137 cm  FROM TOP
        A MEASURED AT  91 cm FROfl TOP

        Q MEASURED At  46 cm FROM TOP
                                  0

                                                         •

       	.	1	,	m W.    .	I	. a M  .     .     I
               -i
                                0
+1
                         DISTANCE FROM CENTER OF SLOT, m

                   Figure 3.  Velocity profile of an air curtain.
                                438

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 01
 "c
 o
 [/i
U
13
                                                                               i  O  1.27  cm
                                                                                j  A  2.54  cm
                                                                                  El  3.81  cm
                                                                                       500
1000
                                                  —,  dimensionless
           Figure 4.  Measured and predicted  centerline axial  velocity decay.

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s

LiJ
• «
:
 i
. •
• i
        m
        rrrr:.:...:....t:.
        10
100

x/w, m/m
500
1000
        Figure 5.   Measured  and  predicted air entrainment ratio.
                                        440

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                                                                                            POWER SUPPLY
--
--
                     BLOWER
                                          FLOW
                                       STRAIGHTENING
                                         SECTION
                                            \
  INLET
SAMPLING
 SECTION
 SPRAY
SECTION
   PARTICLE
   CHARGING'
    SECTION
                                                                                i • H
                                                                                               SUMP
 OUTLET
SAMPLING
 SECTION
                               ,ENTRAINDENT
                                SEPARATOR
VENT
                               Figure 6.    Experimental  apparatus  for  studying charged  spray  section  of
                                             SCAT  scrubber.

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 2
S
       i.o
       0.5
       0.1
      0.05
      0.01
              '. UNCHARGED PARTICLE/NEUTRAL
                 4-U-l
             . . .
              . . :  . ,
: UNCHARGED PARTICLE/CHARGED  DROP'
                                      ".I....I

                     =  2.9 m/s
                 QL/QG  =  4 x 10   mVra
                 Nozzle  A
                 1 Spray bank



                        .






                                        ill



          0.1
         0.5
1
10
                       AERODYNAMIC  PARTICLE DIAMETER, ymA
           Figure 7.  Measured spray  scrubber penetration,  nozzle A.
                                      442

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   UNCHARGED PART./NEUTRAL DRO
            ART./NEUTP.AL...D
            1 1 l l l l l i fr i i i i . IT 1111IIII I II II I )L J
   UNCHARGED PART./CHARGED
        -CHARGED PART./CHARGED DROP
           =  2.9 m/s
       Q, /Qr  =  7 x 10'4 mVm3
        L'XG
       NOZZLE  i;
       TEST PARTICLES - HYDRATED  LIME
              AERODYNAMIC PARTICLE DIAMETER, ymA

Figure 8.   Measured SCAT spray scrubber performance,  nozzle B.
                           443

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u
2

                           MEASURED^
              UG  =  2.9 m/s

              QL/QG = 7 x 10

              1 SPRAY BATIK
              NOZZLE =  B.
              NOZZLE PRESSURE = 423  kPa
              UNCHARGED PARTICLE/NEUTRAL DROP
     0.05
    0.01
                            0.5         1

                      AERODYNAMIC PARTICLE DIAMETER, ymA
       Figure 9  •  Predicted and measured spray scrubber penetration, nozzle B.
                                    444

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           x
           s
                                                                                 Air

                                                                              Curtain
SCAT Scrubber
FURNACE
                     Figure  10.   Hot  source experiment.

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     CONTAIN/CONVEY DUST
GUTTER
 BROOM
                    AIR  INTAKE
                         i
 DUST
PICK-UP
HOPPER
CHARGED
 SPRAY
                                                                            EXHAUST
                              RECIRCULATED  AIR
                      FIGURE 11.   Improved Street Sweeper

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