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CORPORATION
EXECUTIVE SUMMARY
AN AIR POLLUTION COMPLIANCE
ANALYSIS REPORT ON NINE
INDUSTRIES
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RAMAGfl
CORPORATION
EXECUTIVE SUMMARY
AN AIR POLLUTION COMPLIANCE
ANALYSIS REPORT ON NINE
INDUSTRIES
PRIMARY ALUMINUM NITRIC ACID
FERROALLOY PHOSPHATE FERTILIZER
PORTLAND CEMENT COAL CLEANING
SULFURIC ACID GRAY IRON
ASPHALT CONCRETE
Presented to:
Mr. Robert C. Marshall, Project Officer
U.S. Environmental Protection Agency
Division of Stationary Source Enforcement
Waterside Mall
401 M Street, S.W.
Washington, D.C. 20460
2 December 1975
Prepared by:
B. P. Cerepaka, Task Director
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CORPORATION
This Executive Summary presents a review of an
extensive compliance analysis study of nine major
industries performed for the U.S. Environmental
Protection Agency in fulfillment of contracts
68-02-1319, Task 16 and 68-02-1383, Task 11.
Reports for each of the nine industries are presented
in individual volumes. EPA Proj ect Officer was
Mr. Robert C. Marshall. Radian Program Manager
was Mr. C. P. Bartosh. Mr. B. P. Cerepaka was
Task Director. The contents herein do not neces-
sarily represent the views or policies of the Agency.
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CORPORATBON
TABLE OF CONTENTS
Page
1.0 BACKGROUND 1
2.0 SCOPE 2
3.0 APPROACH 7
4.0 RESULTS 10
LIST OF TABLES
Page
2.0-1 SUMMARY OF PRODUCTS, OPERATIONS, AND POLLUTANTS. . 6
4.0-1 SUMMARY OF INDUSTRY PRODUCTION AND
POTENTIAL PARTICULATE EMISSIONS. 11
4.0-2 CATEGORICAL SUMMARY OF PLANT COMPLIANCE STATUS
BY INDUSTRY 13
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CORPORATION
1.0 BACKGROUND
Under Section 113 of the Clean Air Act, as amended,
the Administrator of the Environmental Protection Agency (EPA)
may initiate federal enforcement against any "person" responsible
for the violation of an applicable requirement set forth in
the State Implementation Plans (SIP), the New Source Performance
Standards (NSPS), or the National Emissions Standards for
Hazardous Air Pollutants (NESHAPS).
Although each of the ten EPA regional offices has
primary responsibility for implementation of the Administrator's
federal enforcement authority, the Division of Stationary
Source Enforcement in EPA headquarters is responsible for over-
all enforcement policy development. By maintaining a national
overview of the compliance status of air pollution sources, as
well as the mitigating factors which have produced this status,
DSSE is able to provide uniform guidance to the regional offices
involved in federal enforcement activities.
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CORPORATION
2.0 SCOPE
Radian Corporation has performed an extensive com-
pliance analysis study of nine major industries: primary
aluminum, ferroalloy, portland cement, sulfuric acid, nitric
acid, phosphate fertilizer, coal cleaning, gray iron, and asphalt
concrete. The initial goal of the study was to locate all
facilities with production capabilities. In addition, indivi-
dual plant processes and size (capacity and production) were
located for calculation of potential (uncontrolled) emissions
from EPA emission factors and for calculation of allowable
emissions based on state air quality implementation plans (SIP).
Actual emissions for individual plants were extracted from the
National Emissions Data System (NEDS) and were supplemented by
industry wide estimates made in other studies. Individual plant
compliance status was obtained from the Compliance Data System
(CDS) and was supplemented by manual file data from the regional
offices.
The following section presents the definition of each
industry for this study including the pollutants and processes
that were considered.
Primary Aluminum - the scope of this industry was
restricted to all primary aluminum smelters. Bauxite plants
were not considered. The reduction process including anode
baking was the operation considered. Total particulates and
total fluorides were the pollutants studied from reduction
operations. This industry is classified by the Standard
Industrial Classification Manual as SIC 3334.
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CORPORATION
Ferroalloy - the scope of this industry is defined by
the products. In this study the definition is the same as
given by the Bureau of Mines Minerals Yearbook and includes
such products as ferromanganese, silicomanganese, ferrosilicon
(including silicon metal), chromium alloys, ferrotitanium,
ferrophosphorus, and miscellaneous others. The industry is
classified by SIC 3313, except for plants which produce ferro-
alloys primarily in blast furnaces which are under SIC 3312.
The major process considered is the electric smelting furnace,
although other types of production processes are considered.
Paritculates are the only pollutant considered.
Portland Cement - this industry was defined to include
all plants which produce clinker and also those which only
finish grind clinker produced elsewhere. The industry is
classified by SIC code 3241. The operations considered were
grouped into dryers, grinders and kiln, cooler. Particulates
were the only pollutant considered.
Sulfuric Acid - plants producing sulfuric acid by two
types of processes were considered: contact and chamber
processes. The absorption column is the major emission process
point. Sulfur dioxide and acid mist (particulate) were the
pollutants studied. The industry is classified by SIC code 2819.
Nitric Acid - nitric acid production including con-
centrated acid production was the scope of this industry. The
absorption column is the major emission process point. Nitrogen1
oxides is the pollutant considered. The industry is classified
by SIC code 2873.
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eORPORATOON
Phosphate Fertilizer - the scope of this industry
is defined as those plants which chemically manufacture the
three fertilizers: normal superphosphate, triple (concentrated)
superphosphate, and ammonium phosphates. The industry is
classified by SIC code 2874. Normal superphosphate production
emissions are particulate and fluoride from the main stack and
dryers, grinders. Triple superphosphate production emissions
are fluorides from the alternative types: run-of-pile and
granular. Ammonium phosphate production emissions are parti-
culates and fluorides from the dryer, cooler and ammoniator -
granulator.
Coal Cleaning - the scope of this industry is defined
to include all plants which mechanically clean, wash, and
prepare coal by wet or dry methods. Also included are all
plants which thermally dry cleaned coal. Coal tipple plants
are not included in this study. The thermal dryer is the major
emission-producing operation at coal preparation plants.
Particulate emissions are the most important air pollution pro-
blem. The coal cleaning industry is classified by SIC code
1211 for bituminous coal and 1111 for anthracite coal.
Gray Iron - this industry is defined to include all
those iron foundries which produce gray or ductile iron cast-
ings. Foundries which produce only malleable iron are ex-
cluded. The gray iron industry is classified by SIC code 3321.
Metal melting is the operation producing the most emissions at
gray iron foundries. Three types of furnaces and two pollutants
are considered: cupolas, particulate and carbon monoxide
emissions; reverberatory furnaces, particulate emissions;
and induction furnaces, also particulate emissions.
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COREPORATBON
Asphalt Concrete - the scope of this industry is de-
fined to include all "hotmix" asphalt concrete plants, both
stationary and portable. The industry is classified by SIC
code 2951. The rotary dryer is the major emission-producing
operation at asphalt concrete plants. Particulates are the
major pollutant.
Table 2.0-1 is a summary of the products, operations,
and pollutants considered for each industry in this study.
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TABLE 2.0-1
SUMMARY OF PRODUCTS, OPERATIONS, AND POLLUTANTS
INDUSTRY
Primary Aluminum
Ferroalloy
Portland Cement
Sulfuric Acid
Nitric Acid
Phosphate
Fertilizer
Coal Cleaning
Gray Iron
PRODUCT(S)
aluminum ingot
ferrosilicon
silicomanganese
chromium alloys
ferrotitanium
ferrophosphorus
others
Portland Cement
sulfuric acid
nitric acid
normal superphosphate
triple superphosphate
ammonium phosphates
cleaned coal
gray and ductile iron
OPERATION(S)
reduction cells
anode bake furance
electric smelting furance
dryers, grinders
kiln, cooler
absorber
absorber
grinding, drying, main stack
run-of-pile, granular
dryer, cooler, ammoniator-
granulator
thermal dryers
cupola
reverberatory furance
induction furnace
P OLLUTANT(S)
particulates, fluorides1
particulates
particulates
particulates
particulates
particulates, sulfur dioxide1
nitrogen oxides
particulates, fluorides1
particulates
particulates
particulates
particulates, carbon monoxide
particulates
particulates
Asphalt Concrete asphalt concrete
rotary dryer
particulates
1 Emissions summarized in specific industry report
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CORPORATION
3.0 APPROACH
Radian was supplied plant summaries as of August, 1974
from NEDS and CDS selected by SIC code appropriate to each industry.
The first step was to obtain as much data as possible from non-EPA
sources. Industry surveys, trade journals, association membership
lists, Bureau of Mines, and others provided plant locations, sizes,
and processes. The Bureau of Census provided industry-wide totals
of production and numbers of operational plants. Radian was unable
to confirm operational status of the individual plants located be-
cause the Bureau of Census does not divulge name and location of
individual plants. All plants were then grouped into EPA regions,
states, AQCR's, counties, and cities. Each planted located from
non-EPA sources was assigned coding numbers for state, county, and
city from the SAROAD Station Coding Manual. Pollutant priorities
for each AQCR were located in 40 CFR 52 (revised as of July 1, 1974)
The next task was to record the actual compliance status
and compliance schedules, if any, for each plant.on the lists.
This task was broken down into two areas; those plants in CDS, and
those not.
Those sources in CDS were evaluated for overall plant
compliance by using a "Quick Look" Report summary of the entire
source (plant) created in May, 1975. Schedules were obtained from
Source Data Reports selected by the applicable SIC code for each
industry. Schedules for plants not identified in the SIC code
search were obtained by selecting a "Quick Look" Report for all
increments of progress which were scheduled on January 1, 1975 or
later. Schedules for plants in CDS which did not appear in the
Source Data Reports selected on SIC code or in the "Quick Look" Re-
port for increments of progress due beyond 1974 were not obtained.
In many cases, these plants were listed in CDS with an incorrect
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Bmis
CORPCDRAVBON
entire plant status code. Therefore, many of the plants actually
having unknown compliance with increments of progress of a schedule
appeared in CDS with a code for unknown compliance with emission
limitations. Radian's report for each industry reflects this error.
Status of those plants not in CDS was obtained from regional
offices, if known. The Regional Offices were also queried about
any manual file data available to update CDS. In some cases, data
was in the process of being added to CDS and was unavailable for
this study. The following is a summary of the supplemental Region
Office data which was available and used in this study.
Region I - None
Region II - CDS Source Data Reports for all sources
as of 23 April 1975. Data was obtained
by a visit to Regional Office on 23 April
1975.
Region III - None
Region IV - CDS Source Data Reports for all sources
and Semi-annual and Quarterly Reports from
the states in Region IV. This data was
available to Radian as a result of an on-
going contract with Region IV to update
CDS
Region V - None
Region VI - CDS Source Data Reports for Louisiana and
Oklahoma and data from Texas Air Control
Board on compliance status of all sources
in the EMS system as of 30 April 1975.
Region VII - Status of all sources was obtained by visit
to Regional Office on 21-23 April 1975.
Region VIII - Status of all sources as of 21 May 1975
was obtained by mail contact.
Region IX - The status of nine sources in neither NEDS
nor CDS was obtained over the phone. Status
was as of 23 May 1975.
Region X - None
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§3£l35SA&a
eoRpmutnoN
Radian attempted to perform calculations of potential
and allowable emissions on individual plant data collected from
non-EPA data sources. The purpose was to make state, regional,
and national comparative summaries of the emission levels allowed
by SIP's relative to potential emissions. Calculations of poten-
tial and allowable emissions for each plant could not uniformly
be made for all industries. However, for those industries for
which individual plant data was insufficient to choose the proper
emission factor, an average factor was applied to national pro-
duction to estimate total industry potential emissions. For
those industries in which allowable emissions could not be
accurately calculated on a plant-by-plant basis, Radian used
estimates made in other studies to determine approximate nation-
wide average control efficiencies required by the SIP's. Also
consulted was 40 CFR 51 - Appendix B ^ Examples of Emission
Limitations Attainable with Reasonably Available Technology.
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CORPORATION
4.0 RESULTS
National total of potential (uncontrolled) emissions
for each industry using EPA emission factors and production from
the latest year in which data was available were calculated.
Total potential particulate emissions were about 21,578,000
tons for the eight industries with particulate emission factors
(nitric acid is the exception). Potential S02 emissions from the
sulfuric acid industry vary substantially according to the per-
cent conversion of SO2 to S03 in the process. An average con-
version percentage for the industry could not be obtained so
potential emissions were not estimated. Potential NC>x emissions
from nitric acid production were calculated to be 271,000 tons.
Potential carbon monoxide emissions from the gray iron industry
were calculated to be 1,300,000,000 tons. Refer to Table 4.0-1
for an industry by industry summary of number of plants, produc-
tion, and potential particulate emissions.
The number of plants located for each industry in this
study relative to the number of operating plants as reported by
Bureau of Mines and Bureau of the Census differ for some industries.
The number of plant locations found in this study for each industry
are presented in Table 4.0-2. The number of sulfuric acid
plants located by Radian is about 100 greater than the number
reported operating in 1974. Radian included many small chamber
sulfuric acid plants which are probably closed. These plants
were preserved in this study because the Census Bureau does not
report names and addresses of producing plants, only numbers.
So Radian could not determine which of the plants were operating.
The case for the phosphate fertilizer industry is similar in
that over 150 more plants were found by Radian than were re-
ported to be operating in 1973. Many of these are small normal
superphosphate plants which have closed. For two industries,
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TABLE 4.0-1
SUMMARY OF INDUSTRY PRODUCTION AND POTENTIAL PARTICULATE EMISSIONS
INDUSTRY YEAR
Primary Aluminum ^ 1973
Ferroalloy 1972
Portland Cement 1973
Sulfuric Acid 1974
Nitric Acid 1973
Phosphate 1973
Fertilizer
Coal Cleaning 1972
Gray Iron 1972
Asphalt Concrete 1972
OPERATING
PLANTS PRODUCTION (TONS)
31 4,529,000
47 2,526,000
173 83,476,000
150 32,234,000 (100% acid)
85 9,872,000 (100% acid)
92 5,231,000 (P205)
408 292,829,000
(Mechanically cleaned)
'VLSOO 18,024,000
^4800 325,000,000
SOURCE OF
PRODUCTION DATA
Bureau of Mines
Bureau of Mines
Bureau of Mines
Bureau of Census
Bureau of Census
Bureau of Census
OPERATIONS CONSIDERED
Reduction cells, anode
furnaces
Electric furnaces
Dryers, Grinders,
Kiln, Cooler
Absorber
Absorber
Normal Super, Triple
Super, and Ammonium
Phosphate Manufacturing
Bureau of Mines, Thermal Dryer
Bureau of Census
National Asphalt
Pavement Associa-
tion
Cupola
Rotary Dryer
POTENTIAL
PARTICULATE
EMISSIONS
201,000 tons
138,000 tons1
12,400,000 tons
66,000 tons
275,000 tons2
532,000 tons3
154,000 tons
7,312,000 tons
21,578,000 tons
1 Emission factors applicable to 71% of production
2 Emission factors applicable to 68% of P2O5 production
3 Emission factors applicable to thermally dried coal, which was 18% of cleaned coal
4 Of these, 112 plants operated 155 thermal drying units.
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CORPORATION
gray iron and asphalt concrete, Radian was unable to locate all
the plants. The number of gray iron plants located was about 56%
of total thought to be operating. The number of asphalt plants
located number about 35% of the estimated number operational.
For the remaining industries, Radian's total is very near the
number reported to be operating.
Compliance status data for the sources in each industry
was compiled into three categories: in compliance, out of com-
pliance, and unknown. These categories were subdivided into six
subcategories: in compliance with SIP emission limitations as
determined by source test, inspection or state certification; in
compliance with the increments of progress of a compliance schedule;
out of compliance with emission limitations; out of compliance
with the increments of progress of a compliance schedule; unknown
compliance with emission limitations; and unknown compliance with
the increments of progress of a compliance schedule.
Table 4.0-2 presents an industry by industry summary
of the number of plants and percentages reported to be in, out,
and unknown compliance as of May, 1975.
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TABLE 4.0-2
CATEGORICAL SUMMARY OF PLANT COMPLIANCE STATUS BY INDUSTRY
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TOTAL
UNKNO
TOTAL
Primary Aluminum
9
2
11
1
3
4
12
4
16
31
(29%)
(6%)
(35%)
(3%)
(10%)
(13%)
(39%)
(13%)
(52%)
Ferroalloy
3
2
5
3
6
9
24
19
43
57
(5%)
(4%)
(9%)
(5%)
(11%)
(16%)
(42%)
(33%)
(75%)
Portland Cement
40
21
61
9
10
19
82
30
112
192
(21%)
(11%)
(32%)
(5%)
(5%)
(10%)
(43%)
(15%)
(58%)
Sulfuric Acid
41
15
56
10
8
18
146
41
187
261
(16%)
(5%)
(21%)
(4%)
(3%)
(7%)
(56%)
(16%)
(72%)
Nitric Acid
11
12
23
10
4
14
54
16
70
107
(10%)
(11%)
(21%)
(9%)
(4%)
(13%)
(51%)
(15%)
(66%)
Phosphate Fertilizer
14
4
18
6
4
10
197
36
233
261
(5%)
(2%)
(7%)
(2%)
(2%)
(4%)
(75%)
(14%)
(89%)
Coal Cleaning
61
0
61
1
3
4
380
26
406
471
(13%)
(0%)
(13%)
(0%)
(1%)
(1%)
(81%)
(5%)
(86%)
Gray Iron
167
47
214
12
13
25
457
145
602
841
(20%)
(6%)
(26%)
(1%)
(1%)
(2%)
(55%)
(17%)
(72%)
Asphalt Concrete
326
20
346
23
10
33
1,032
255
1,287
1,666
(20%)
(1%)
(21%)
(12)
(1%)
(2%)
(62%)
(15%)
(77%)
TOTAL
672
123
795
75
61
133
2,384
572
2,956
3,887
(17%)
(4%)
(21%)
(2%)
(1%)
(3%)
(61%)
(15%)
(76%)
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