United States         Office of Enforcement      EPA-68-01-41-13
            Environmental Protection     Office of General Enforcement   October 1979
            Agency          Division of Stationary Source    Washington, DC 20460
                        Enforcement
&EPA      Instructional Manual
            for Clarification of
            Startup in Source
            Categories Affected
            by New Source
            Performance Standards

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                                                             GCA-TR-79-33-G
                     U.S.  ENVIRONMENTAL PROTECTION AGENCY
                           Washington,  D.C.   20460
     EPA Project Officer
         John Busik
Division of Stationary Source
         Enforcement
     401 M Street,  S.W.
   Washington, D.C.  20460
      EPA Task Manager

        Robert Myers
Division of Stationary Source
         Enforcement
     401 M Street, S.W.
   Washington, D.C.  20460
                            Contract No.  68-01-4143
                            Technical Service Area 1
                               Task Order No. 62
                    INSTRUCTIONAL MANUAL FOR CLARIFICATION

                       OF  STARTUP IN SOURCE CATEGORIES

                           AFFECTED BY  NEW  SOURCE

                           PERFORMANCE  STANDARDS
                               Final Report
                                 October 1979
                                      by

                             Douglas R.  Roeck
                             Peter tt.  Anderson
                             Philip S. Hincman
                             Robert G. Mclnnes
                             William F.  Ostrowski

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                                  DISCLAIMER
     This Final Report was furnished to the Environmental Protection
Agency by GCA Corporation, GCA/Technology Division, Burlington load, Bedford,
Massachusetts 01730, In fulfillment of Contract No. 68-01-4143, Technical
Service Area 1, Task Order No. 62.  The opinions,  findings,  and conclusions
expressed are those of the authors and not necessarily those of the Environ-
mental Protection Agency.  Mention of company or product names is not to be
considered as an endorsement by the Environmental  Protection Agency.

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                                  ABSTRACT
     New Source Performance Standards promulgated for 27 source categories
specify that performance testing shall be conducted within certain time
.periods of startup for each affected facility.  This manual discusses initial
startup for each new facility subject to these regulations and provides the
technical basis for uniform application of the regulations pertaining to
source testing.
                                     Ill

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                                  CdNTENTS
Abstract . . .	  ill
Figures  ....... 	 ...... 	  vli

     1,   Introduction and Summary ...........	    \
               Introduction  ......................    1
               Summary	,    2
     2.   Industrial Summaries 	 ........    4
               Source Listing  	 ...    4
               Fossil Fuel-Fired Steam Generators - Subpart D
                 §60.40 - 60.46	    6
               Incinerators - Subpart E
                 §60.50 - 60.54  ........... 	   10
               Portland Cement Plants - Subpart F
                 §60.60 - 60.64  .	  ..........   14
               Nitric Acid Plants - Subpart G
                 §60.70 - 60.74	   20
               Sulfurlc Acid Plants - Subpart H
                 §60.80 - 60.85	   25
               Asphalt Contrete Plants - Subpart I
                 §60.90 - 60.93	   29
               Petroleum Refineries - Subpart J
                 §60.100 - 60.106  .  . •	   35
               Storage Vessels for  Petroleum Liquids  - Subpart K
                 §60.110 - 60.113	    42
               Secondary Lead Smelting - Subpart L
                 §60.120 - 60.123	    44
               Secondary Brass and  Bronze Ingot Production Plants -
                 Subpart M   §60.130 - 60.133	    48
               Iron and Steel Plants - Subpart  N
                 §60.140 - 60.144	    53
               Sewage Treatment Plants - Subpart 0
                 §60.150 - 60.154	    57
               Primary Copper Smelters - Subpart P
                 §60.160 - 60.168	    63
               Primary Zinc Smelters - Subpart  Q
                 §60.170-60.176	    69
               Primary Lead Smelters - Subpart  R
                 §60.180 - 60.186	    74
               Primary Aluminum Reduction Plants - Subpart  S
                 §60.190 - 60.195	    80
               Wet  Process - Phosphoric  Acid Plants - Subpart T
                 §60.200  - 60.204	    85

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             CONTENTS  (continued)
Superphosphoric Acid Plants - Subpart U
  §60.210 - 60.214	89
Diaimnonium Phosphate Plants - Subpart V
  §60.220 - 60.224	  94
Triple Superphosphate Plants - Subpart W
  §60.230 - 60.234	98
Granular Triple Superphosphate Storage Facilities -
  Subpart X   §60.240 - 60.244	102
Coal Preparation Plants - Subpart Y
  §60.250 - 60.254	105
Ferroalloy Production Facilities - Subpart Z
  §60.260 - 60.266	108
Iron and Steel Plants:  Electric Arc Furnaces
  Subpart AA   §60.270 - 60.275	113
Kraft Pulp Mills - Subpart BB
  §60.280 - 60.285	116
Grain Elevators - Subpart DD
  §60.300 - 60.304	124
Lime Manufacturing Plants - Subpart HH;
  §60.340 - 60.344	129
                      vi

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                                    FIGURES

Number

  1      Simplified flow diagram of a fossil fuel-fired
           steam generator	- .	  7

  2      Schematic diagram for a continuous feed municipal
           incinerator	11

  3      Conventional dry process cement plant  	 ... 15

  4      Suspension preheater cement plant 	  .... 	 .16
                                                       t

  5      Flow diagram for nitric acid production by the
           pressure process  ..... 	 .  	 21

  6      Schematic diagram of two processes for manufacturing
           sulfuric acid ................  	 ...26

  7      Schematic diagram of a typical batch asphalt concrete
           plant	31

  8      Plow diagram for catalytic cracking process ........... 36

  9      Flow diagram for a typical three-stage claus sulfur
           recovery plant  ....... 	  .....  	 39

 10      Brass and bronze ingot production facility  .	• ^'

 11      BOPF Steelmaking process flow diagram  ....... 	 54

 12      Sewage sludge Incinerator process diagram .... 	 58

 13      Sewage sludge wet air oxidation process diagram  ......... 59

 14      Flow diagram for copper smelting and various unit
           processes	 64

 15      The pyrometallurgical process 	 ............ 71

 16      Lead smelting flow diagram with typical process  units 	 75

 17      Process flow diagram for primary aluminum reduction ....... 81
                                      vii

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                             FIGURES (continued)

Number                                                                   Page

 18     Flow diagram of the v.'et-process phosphoric acid
          production process .... 	   86

 19     Superphos'phoric acid production by the vacuum
          evaporation process  ....  	   90

 20     Superphosphoric acid production by Che submerged
          combustion process	•	• •   91

 21     Process flow diagram for diannnonium phosphate production ....   95

 22     Flow diagram for triple superphosphate manufacturing
          process	   99

 23     Granular triple superphosphate  storage plant 	  103

 24     Schematic diagram of the ferroalloy production process 	  110

 25     Flow diagram for Kraft  pulping  process operation .	  118

 26     Process flow diagram for grain  terminal elevators  	  126

 27     Process flow diagram for lime calcination and
          hy drat ion	  130
                                   viii

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                                ACKNOWLEDGMENT
     The authors wish to thank Mr. Robert Myers, the EPA Task Manager, for his
guidance throughout the program.  He acknowledge Mr. Norman Surprenant of
GCA/Teehnology Division, who provided a critical review of this document.
Finally we would like to thank Mr. Paul Exner of GCA -for his contribution to
the manual.

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                                  SECTION 1

                           INTRODUCTION AND SUMMARY
INTRODUCTION

     Since 1971, New Source Performance Standards (NSPS) have been promulgated
by the U.S. Environmental Protection Agency for twenty-seven (27) industrial
categories.  Section 60.8 of Title 40 of the Code of Federal Regulations (CFR)
specifies conditions for conductance of performance tests for determining
compliance with the regulations.  Paragraph(a) states in part that performance
tests are to be conducted "within 60 days after achieving the maximum production
rate at which the affected facility will be operated, but not later than 180
days after initial startup of such facility ..."  Startup is defined under
Part 60.2, paragraph (o), as "the setting in operation of an affected facility
for any purpose."  The general nature of this definition could result in a
nonuniform interpretation of "startup" by enforcement personnel as applied to
various source categories.

     The purpose of this manual, therefore, is to provide concise, descriptive
summaries of the regulated industries including all operations and procedures
related to the startup of a new facility.  These industrial "profiles" will
provide a common basis upon which decisions can be made with respect to the
proper time for performance testing.  This is an important decision since test-
ing at less than optimum conditions can yield erroneous and unrepresentative
results as well as incurring additional costs upon th'e source operator.

LIMITATIONS

     This manual should not be used as a substitute for meeting NSPS require-
ments as presented in the Federal Register or Code of Federal Regulations,  since
the summaries in this manual do not contain all of the requirements a source
must meet in performance testing.  Additionally, new standards are nearing
promulgation and current standards are being revised; this manual represents
standards in effect only through March, 1979.

EFFECTIVE DATE

     Each source section in this manual contains an effective date.  Any source
in that category constructed,  reconstructed or modified after the effective
date is subject to the applicable NSPS.

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PROJECT APPROACH

     Technical information for this manual has been solicited primarily from
process engineers employed at the industries involved.  Additional data have
been obtained from trade associations, equipment suppliers or contractors, and
technical Journals and publications.

ArPLlCATlOfl OF FINDINGS

     The startup definitions specified for each industry have been geared
towards normal or typical circumstances in which all equipment is delivered
and tested on schedule and no major malfunctions occur during initial startup
or subsequent process evaluation.  This manual points out several source cate-
gories where problems might be encountered in meeting the 180 day deadline.
In these Instances, enforcement personnel will evaluate the situation on a
case-by-case basis.  It must be stressed that not obtaining maximum production
rate within 180 days (as may occur with the kraft pulp mill, nitric acid plant,
or primary aluminum industry, for example) is not sufficient reason for delay
of performance tests; tests could be required during the 180 day period and
again when maximum production is reached.

SUMMARY

   .  Contacts with the various industries involved in each of the NSPS cate-
gories have resulted in many similar circumstances regardless of source type,
which affect new source startup.  Items which generally apply to any source
category are:

     •    The desire to come pn-stream as soon as possible so as to
          minimize extensive startup periods which would result in
          excessive capital expenditures with no Immediate cash flow return.

     •    Training of operating personnel can be very important if exper-
          ienced people cannot be obtained from another plant location.

     •    Most plants initially undergo mechanical acceptance of process
          equipment which is partially carried out by the contractor or
          equipment supplier and partially carried out by the source
          owner or operator.

     •    Following mechanical acceptance,  process performance evaluation
          is conducted,  usually in the form of a demonstration or test
          run,  resulting in the acceptance  of the plant from the contractor.

     Some specific procedures or operations that may be carried out  for par-
ticular pieces  of equipment are:

     •    Water  batching of liquid vessels' for leak detection and
          instrument  calibration,

     •    Gradual firing and curing of equipment  containing  refractory
          material,

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     •    Hydrostatic or pressure testing of fossil fuel-fired vessels
          according to specific codes, and

     •    Dry operation of mechanical mixing, granulating, conveying,
          and transporting systems.

     Other aspects of plant startup which regulatory people need to be familiar
with pertain to the phenomenon of engineering scale.  Scale-up problems are
bound to occur since most new plants tend to be larger in capacity than existing
ones and also attempt to incorporate innovative designs relative to energy-
efficiency.  New facilities constructed for a known process of nominal design
production rate would likely require much less time than a new plant built for
a prototype process or a much larger plant.

     The industrial surveys conducted have resulted in several common suggestions
for definition of an initial plant startup, irrespective of the industry
involved:

     1.   24-hours of continuous operation

     2.   Shipment of on-grade product to the customer

     3.   Product from process is used to make a profit or is
          inventoried.

     4.   First introduction of raw material with potential
          for emission of regulated pollutant(s)

     5.   Mechanical acceptance of plant

     6.   Completion of successful demonstration run

     7.   Contractual acceptance of plant

     The selection of startup for each industry has been based upon a composite
of three criteria; the theoretical position of an enforcement agency (No.  4
above), the viewpoint of industrial contacts (all of the above),  and the ability
of a source category to achieve rated capacity within 180 days of the selected
startup point.

GOOD AIR POLLUTION CONTROL PRACTICE DURING STARTUP

     After the  effective date of an NSPS,  an applicable source must meet the
standard except during times of startup,  shutdown, or malfunction.   The source
owner or operator must at all times,  including startup,  maintain  and operate
any affected facility in a manner consistent with good air pollution control
practice (40 CFR 60.11(d)).   Hence,  atmospheric emissions during  the startup
period must always be directed through pollution control equipment.

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                                  SECTION 2
                             INDUSTRIAL SUMMARIES

SOURCE LISTING
     The twenty-seven (27)  source categories currently affected by NSPS which
are the subject of this report are listed as follows:
     1.   Fossil fuel-fired steam generators
     2.   Incinerators
     3.   Portland cement plants      =
     4.   Nitric acid plants
     5.   Sulfuric acid plants
     6.   Asphalt concrete  plants
     7.   Petroleum refineries
     8.   Storage vessels for petroleum liquids
     9.   Secondary lead smelters
    10.   Secondary brass and bronze ingot production  plants
    11.   Iron and steel plants
    12.   Sewage treatment  plants
    13.   Primary copper smelters
    14•   Primary zinc smelters
    15.   Primary lead smelters
    16.   Primary aluminum  reduction plants
    17.   Wet-process phosphoric acid plants
    18.   Superphosphoric acid plants
    19.   Diammonium phosphate plants
    20.   Triple superphosphate plants
    21.   Granular triple superphosphate  plants
    22.   Coal preparation  plants
    23.   Ferroalloy production facilities

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    24.   Steel plants:  electric arc furnaces

    25,   Kraft pulp mills
    26.   Grain elevators

    27.   Lime manufacturing plants

     The detailed summaries that follow are arranged in the same order as the
preceding list and as they appear in CFR Part 60.  Each summary is self-
supporting and contains the following sections:

     *    Introduction - Brief description of equipment and pollutants
          regulated and the effective date of the standard.

     *    Proceaa Pegcription - Discussion of process(es)  associated
          with each industry with a flow diagram if required for equip-
          ment/process clarification.

     *    Preatartup Operations - Discussion of equipment  shakedown
          and debugging procedures, tine involved, and types of prob-
          lems encountered.

     *    Startup Operations - Definition of best startup  points for
          each category, time and specific procedures involved, and
          duration of operation prior to achieving maximum (or design)
          production rate.   Also, discussion of any unusual
          circumstances.

     •    References - Listing of industrial contacts, equipment
          suppliers or other technical literature.

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              FOSSIL FUEL-FIIED STEAM GENERATORS - SUBPART, D
                               §60.40 - 60.46
 Introduction

     The NSPS  for this category encompasses  fossil  fuel-fired  or  fossil  fuel
 and wood residue-fired steam generating units capable of operating at  greater
 than 73 MW  (250  x 106 Btu/hr) heat input.  Performance standards  were  pro-
 mulgated for nitrogen oxides, particulate matter, sulfur dioxide,  and  opacity.
 Sulfur dioxide and nitrogen oxides are regulated according  to  the type of
 fuel fired, (i.e., gaseous, liquid, or solid fuels).  Particulate matter is
 limited to  43  ng/J (0.1 lb/106 Btu) input.  Opacity is limited to 20 percent
 except for  one 6<-minute period/hr during which  the  opacity  cannot exceed 27
 percent.  Continuous monitoring is required  for S02, NOX, and  opacity.
 Sources constructed, reconstructed or modified  after August 17, 1971,  are
 subject co  the standard with one exception; the effective date for the NOx
 provisions  for lignite-fired units is December 22,  1976; all other provisions
 apply to lignite-fired units constructed, reconstructed or  modified after
 August 17,  1971.

 ProceBaDescription

     Fossil-fuel is defined in 40 CFR §60.41(b) as natural  gas, petroleum, coal,
 and any form of  solid, liquid, or gaseous fuel derived from such materials.
 These fuels are  combusted to create heat in the boilers for the production
 of steam,  fhe steam, in turn, is used, in the case of an Industrial facility,
 to provide heat  and hot water, or to run process equipment, and,  in the  case
 of an electrical utility, to drive multi-stage turbines that produce elec-
 tricity for sale to regional power networks.  See Figure 1.

 Pre-Startup Operations

     Prior to  startup, certain operations are undertaken to ready  the  boiler
 for service.   These "shakedown" procedures are necessary to protect pressure
 parts against corrosion,  overheating, and thermal stresses; prevent furnace
 explosions;  to check for leaks;  and insure the on-line availability of the unit.

     Some of the operations which are Included in the pre-startup category
 Include;

     1.    Filling the boiler and boilout to test components with respect to
 temperature, mechanical stresses,  corrosion resistance,  structural soundness,
warping,  gasketing,  and expansion joints;

     2.    Curing of  refractory material in the boiler and stack and any coatings
present  on heat exchanger surfaces;
                                      6

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                                                  TO ATMOSPHERE
 FUEL
BUNKER /    PREHEATED WATER
                                       / •««•   L
                                       VTMCATMNT JT
     Figure 1.   Simplified flow diagram of a  fossil fuel-fired steam generator.

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     3.   By-passing of the superheater and turbine until desired steam  temper-
ature is reached followed by checking of steam turbine interfacing, controls,
sensors, monitors, load switching, and safety interlocks.

     Many precautions are taken during filling of the boiler  to protect  pressure
parts.  High quality water is used to minimize corrosion and  scale deposits.
To prevent thermal stresses, the temperature gradient between metal and  water
is kept less than 100°F.  Higher temperature differentials would limit the life
of pressure parts and if high enough could cause distortion.  Air is completely
purged from the system through vents to limit oxygen corrosion and assure that
all tubes are filled.  On drum-type boilers, the glass gauge  level should be
about 1 inch of water prior to firing the boiler in order to  fill all circulat-
ing tubes.

     Boilout is necessary to remove all grease and other deposits from interior
boiler surfaces.  It is usually effected with a caustic solution at reduced
temperatures and pressures (as compared to normal operating conditions).  Boil-
out also facilitates the slow curing necessary to condition refractory material.

     These operations enable the detection of defects in materials, fittings,
and welds which can then be corrected without a loss of on-line availability.

     To protect the superheater from overheating, each tube must have sufficient
steam flow to operate properly.  A by-pass system is used to  accomplish  this.
By-pass systems; (a) protect the superheater against shock from water, (b) pro-
vide a means for conditioning water during startup without delaying boiler/tur-
bine warming operations, and (c) reduce temperature and pressure of the  steam
leaving the boiler during startup to conditions suitable for  turbines and
condensers.

     Complete checkout of the superheater and turbine components is thus effected
to ensure that they are completely operational and to detect  any defects in
installation.

     Estimates obtained from several utility companies indicate that these pre-
liminary operations can take from 2 to 12 months depending on such site-specific
factors as equipment delivery schedules and the extent of any encountered prob-
lems.   Industrial facilities would represent the low end of this range while
utility plants would require the longer time periods.

Startup Operations

     For fossil fuel-fired steam generators,  startup is best defined as  the
first  time steam is  produced, by the boiler and used in the case of an indus-
trial  facility,  to provide heat and hot water,  or to run process equipment,  and,
in the case of an electrical utility,  to  drive turbines that produce electricity.

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                                 REFERENCES
1.   Personal Communication with Mr, Smith, Babcock and Wilcox,
     February 28, 1979.
                                  •
2,   Personal Communication with Mr. Williams, Stone and Webster,
     February 28, 1979.

3.   Personal Communication with United Engineers personnel,
     February 28, 1979.

4.   "Steam its Generation and Use", Babcock and Wilcox,
     161 East 42nd Street, New York, NY 10017, 1975.

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                          INCINERATORS - SUBPART I
                               160.50 - 60.54
 Introduction

     The NSPS for this category encompasses incinerators which  burn more than
 50 percent municipal type waste and are capable of charging more  than  45 met-
 ric tons per day (50 tons/day).   Incinerators handling municipal  type  waste
 are generally referred to as municipal incinerators, although they  may be
 owned and operated by either a municipality or a private firm,  A performance
 standard was promulgated for partlculate matter which limits emissions to
 0.18 g/dscm (0.08 gr/dscf) corrected to 12 percent COj.  Sources  constructed,
 reconstructed or modified after August 17, 1971, are subject to the regulation.

 Process Description

     Incineration is defined as the process of burning solid waste  for the
 purpose of reducing the volume of the waste by removing the combustible matter.
 While moat municipal Incinerators have been historically designed solely to re-
 duce the volume of the refuse, an Increasing number are also recovering and
 utilizing the heat generated by this process in the form of steam and  electric
 production.

     The basic components of a municipal incinerator are a) Refuse  holding  and
 Charging, b) Combustion Chambers, c) Air Supply, d) Residue Handling,  and e)
 Air Pollution Control Equipment.  Refer to Figure 2 for a schematic of a typi-
 cal continuous feed installation.  While most incinerators regulated by this
 standard are continuous feed systems, batch systems will have essentially the
 same Integration of component systems.  Refuse Is delivered by  truck to a
 storage pit, from where it is charged to a feed hopper by means of  an  overhead
 crane.  Once in the furnace, the refuse undergoes combustion, in which the
 moisture in the refuse Is first evaporated and then the combustible portion Is
 vaporized and oxidized.  Complete combustion of the refuse is aided by moving
 grates, which may be traveling, reciprocating or rocking types.  Combustion
 Chamber designs may also vary, with rectangular, water walled and rotary kiln
 being the more common types.  Particulate emissions are due to  several factors,
 Including undergrate air velocity, refuse ash content,  burning  furnace
 temperature, grate agitation and combustion chamber design.  Of these,  under-
 grate air velocity has been shown to have the greatest  effect.    Overflre and
 secondary air ports are also provided to increase turbulence and aid in oxi-
dation of the combustible fraction.   Residue la discharged from the end of  the
grates in quench tanks, from where it is hauled to a sanitary landfill.   Com-
bustion gases exiting from the furnace enter a quench chamber or a heat recov-
ery section prior to being vented to an air pollution control device.  Met


                                     10

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                                                                              STACK
                       FEED HOPPEH
                         COMBUSTION
                         CHAMBER
\
COOLING OR
HEAT
RECOVERY
SECTION

              FORCED
              DRAFT FAN
ASH TO
SANITARY
LANDFILL
                                                          AIR
                                                          POLLUTION
                                                          CONTROL
                                                          DEVICE
                               INDUCED
                               DRAFT
                               FAN
Figure 2.  Schematic diagram for  a  continuous  feed municipal incinerator.

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 scrubbers,  electrostatic precipltatators and to a limited extent, fabric fil-
 ters,  have  all  been used to control incinerator partlculate emissions.  Gases
 leaving the control device pass through aa induced draft fan before exiting
 to the atmosphere.

 JPre-^tartup Operations

     A shakedown of all  mechanical and electrical equipment precedes the start-
 up of  a municipal incineration  facility.   Chief mechanical components including
 overhead cranes, shredders,  furnace grate operation,  combustion air supply fans,
 dampers, Induced draft fan,  ash handling equipment and  all pumps connected with
 air pollution control devices and/or boiler feedwater (for units with heat re-
 covery)  are Inspected, adjusted and tested at  this time.   In addition, all
 electrical  equipment including  instrumentation and process control  devices are
 "dry"  (no load) tested and  the  primary ranges  set  on  instrumentation.   These
 checks serve to insure that  the equipment Is operational and has been correctly
 installed.  Pre-startup  teats such as  this are common to all mechanical/electri-
 cal system  installations.   The  real test  of these  components, necessarily comes
 after  facility startup.  Hie last  step prior to startup  Involves the curing of
 the refractory in the furnaces  and  the boilout of  the boiler tubes  with caustic
 for facilities with  heat recovery  capability.   These  two  steps  will occur
 simultaneously and  take  2 to 3  days.   Individual component checks are  typically
 made immediately after component installation.   This  entire pre-startup check
 lasts  2  to  3 months.

jStartyp  Operations

     Startup for municipal incinerators Is  the first  day  refuse  is  fired  Into
 the  incinerator furnace.   The date may be  obtained  from  facility and/or con-
 tractor personnel,  as it marks a transition from installation oriented  person-
nel  to those who service and fine tune the equipment.  Most units are  Initially
run  at only 25 percent load for the first  several days in  order  to check all
equipment for proper clearances, Inspect all expansion Joints and Insure that
there Is no binding or warping of mechanical components  due to thermal  expan-
sion.  Once the facility Is assured that there are no major equipment mating
problems, the refuse feed increases on an Incremental basis.  During this
time, process flow  variables such as furnace and grate temperatures and com-
bustion air flow rates  are monitored and adjusted to give the optimum values.
Since the successful, controlled incineration of municipal refuse Involves
many variables,  this fine tuning may take several months.
                                      12

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                                 REFERENCES
1.   "Systems Study of Air Pollution from Municipal Incineration," Arthur D.
     Little, Inc.  March 1970.  APTD 1283, pp. V-25.

2.   Personal communication with Mr. Maddigan, Refuse Energy Systems Company,
     Saugus, Massachusetts.  March 27, 1979.

3.   Personal communication with Mr. Kirkpatrick, Nashville Thermal Transfer
     Plant, Nashville, Tennessee.  March 23, 1979.

4.   Personal communication with R. W. Beck Associates Personnel, Denver,
     Colorado.   March 26, 1979.

5.   Personal communication with Babcdck and Wilcox Personnel,  Canton, Ohio.
     March 27,  1979.

6.   Personal communication with Dan Schram, Wisconsin Department of Natural
     Resources,  Madison, Wisconsin.  March 26, 1979.
                                      13

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                      PORTLAND CEMENT PLANTS - SUBPAHT F
                                §60.60 - 60.64
Introduction

     This category applies to the following facilities manufacturing portland
cement by either the wet or dry process, regardless of facility size or
material throughput:  kiln, clinker cooler, raw mill system, finish mill sys-
tem, raw mill dryer, raw material storage, clinker storage, finished product
Btorage, conveyor transfer points, bagging and bulk loading and unloading sys-
tems.  Performance standards were promulgated for partlculate matter from
the kiln and clinker cooler, and opacity from any affected facility.  Particu-
late matter emissions from the kiln must not exceed 0.15 kg per metric ton of
feed (dry basis) to the kiln (0.30 Ib/ton).  Particulate matter emissions from
the clinker cooler must not exceed 0.050 kg per metric ton of feed (dry basis)
to the kiln (0.10 Ib/ton).  Opacity for any affected facility is limited to
less then 10 percent, except that gases discharged from the kiln must not ex-
ceed 20 percent opacity.  Sources constructed, reconstructed or modified after
August 17, 1971, are subject to the regulation.

ProcessiDcgcrtption

     lefer to Figure 3 for a flow diagram of conventional cement plants, and
Figure 4 for a diagram of suspension preheater units.  There are four malor
steps in the production of Portland Cement:  Quarrying and crushing, grinding
and blending, clinker production, and finish grinding and packaging.  The
first step, quarrying and crushing, involves mining of the raw materials
(limestone, cement rock, clay, shale and gypsum), on site primary crushing,
transport to the plant, secondary crushing, and raw mill storage.  In the
second step, the raw materials are ground to a powder and blended to the
required composition.  This step will also involve raw material drying or
slurry production depending on whether the dry or wet process is used.  For
suspension pre-heater plants material drying and preheating take place in
a preheater section which immediately precedes the kiln.  After blending,
the ground raw material is fed to a rotating kiln where it is heated, dried,
calcined and finally heated to a point of incipient fusion at about 1,593°C
(2,900°F), a temperature at which a new mineralogical substance called clinker
is produced.  As the clinker is discharged from the kiln,  it passes through a
clinker cooler which serves to reduce the temperature of the clinker before it
is stored, and to recover the sensible heat for reuse in preheating kiln air
supply.   The final step involves proportioning the clinker with gypsum,  grinding
this mixture to a final consistency,  bulk storage of the product, and bagging
and/or bulk loading/unloading of the final product.   The fineness of the raw
and finished product (90 to 100 percent minus 325 mesh) requires that all
transfer points be controlled to prevent emissions.   Emissions are usually
controlled with electrostatic precipitators or fabric filters.

                                      14

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•ULI
rroRMt
»
CLIMEK
•HINIIIN*
Figure 3.  Conventional dry process cement plant.

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                      PEED SUM   KQlL0t»MIU. VffftSS
                                     4-STAGE
                                    SUSPENSION
                                    PRCHEATER
                               BAGGING,
                               SULK LOADING
                               AND  UMLOAOINS
Figure 4.   Suspension preheater cement plant.

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 Pre-startup Operations

      Prior to the passage of any raw material through the various processins
 steps of the facility, all mechanical and electrical systems in each production
 phase are Independently operated.  These checks serve to insure that all motors
 fans, screw conveyors, electrically controlled valves, material handling opera-"
 tlons and air pollution control devices are ready for production.  In wet
 process operations, all pumps and slurry feed systems are also checked at this
 time.  While the real test of these systems comes once the entire facility is
 run under full load conditions, these pre-start up checks screen out Inoperable
 or poorly Installed equipment and therefore minimize down time when the entire
 facility goes on line.

      Once all raw material feed systems  are checked "dry" (without  feed),  raw
 materials are fed into the primary crusher  and follow the processing steps up
 to the kiln feed.   The quantity of material throughput  at this time Is  limited
 to the size of the raw material storage  bins,  typically  one weeks supply.

      The kiln undergoes pre-startup Inspection and  equipment checks of  all
 motors,  bearings,  and  instrumentation.   In  addition,  the refractory of  the
 kiln Is  conditioned by  running  the  unit  at  low fire for  several days.   This
 conditioning  step  is typically  the  last  pre-startup check and  raw feed  into
 the kiln follows  shortly to avoid a second  conditioning  cycle.  Finished
 product  handling,  milling and storage systems  are checked dry  during this
 pre-startup period, as  well.  Cement industry  personnel  Indicated that  approx-
 imately  2 months are needed to  perform all  pre-startup checks, for  both dry
 and wet  process plants.

 Startup  Operations

     Startup  for Portland Cement operations Is generally  considered  to  be  the
 first day raw material  is fed into the preheater or the  kiln, depending on
 facility configuration.  This date is obtainable from plant personnel,  as  it
 Is  often marked by on-slte ceremonies attended by plant,  corporate and  contractor
 officials.  This start-up, however, also begins an Intensive shakedown period
 for  the  facility.  As the production of portland cement  is a chemical process
 Involving many variables, (fuel and feed composition, flow rates, temperatures,
 air  flow rates, etc.) various adjustments to operating parameters must be made
 to produce a  final product meeting desired clinker specifications.  This process
 is a trial and error procedure that may take several months.  In addition, once
 the entire facility begins to operate with feed material, mechanical and elec-
 trical breakdowns occur, delaying the time required to reach full capacity.
 While several cement Industry contractors felt that startup might better be'-
 defined as the first day the plant is run for 24 continuous hours, or the
 first day following 1 month's continuous operation, most agreed that for
 conventional plants, 180 days after Initial kiln firing is sufficient time to
 allow all but the rare cases an opportunity to debug the system, set up the
 process operating parameters and produce at or near rated capacity.   With
modified plants, much of this debugging has already been accomplished,  and
they are online before the 180 days.  For the newer suspension  preheater units,
                                      17

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however, this time frame may not be sufficient.  Contacts with personnel at
plants with these units indicate that more than 180 days may be needed
for equipment shakedown.  This is due to their complexity and the increased
number of interlocks on each phase of production that will shut the entire
plant down, should an upset occur.  These personnel indicated that up to 1
year may be needed to reach normal operation.
                                    18

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                                  REFERENCES
1.   Personal communication with Mr. Steuch, F.L. Stnidth Company, Creskill,
     New Jersey.  March 21, 1979.

2.   Personal communication with Mr. Knoflicek, Mils Chalmers Company,
     Milwaukee, Wisconsin.  March 20, 1979.

3.   Personal communication with Mr. McCord, Portland Cement Association,
     Chicago, Illinois.  March 20, 1979.

4.   Personal communication with F.L. Sraidth Company personnel, Creskill,
     New Jersey.  March 20, 1979.

5.   Personal communication with Lehigh Portland Cement Company personnel,
     Allentown, Pennsylvania.   March 19, 1979.

6.   Personal communication with Southwestern Portland Cement Company per-
     sonnel, Odessa,  Texas.  March 21, 1979.

7,   Personal communication with Mr. Hite, South Dakota Cement Company,
     Rapid City, South Dakota.  March 21, 1979.
                                      19

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                        NITRIC ACID PLANTS - SUBPART G
                                §60.70 - 60.74
Introduction

     This NSPS category regulates weak nitric acid production facilities  (30  to
70 percent strength) that utilize either the pressure or atmospheric pressure
process.  Emissions of nitrogen oxides (NOX), expressed as nitrogen dioxide,  are
limited to 1.5 kg per metric ton (3.0 Ib/ton) of 100 percent nitric acid.  This
is roughly equivalent to about 200 ppm NQX In the tail gas.  Opacity from these
plants is limited to less than 10 percent.  In addition, continuous monitoring
for NOX Is required.  Sources constructed, reconstructed or modified after
August 17, 1971, are subject to these standards.

Prqceaa Description

     The manufacture of nearly all commercial grades of nitric acid in the U.S.
Is accomplished by the single or high-pressure catalytic oxidation of ammonia,
illustrated in Figure 5,  In the process, anhydrous ammonia (NU^) is evaporated
continuously and uniformly In an evaporator using heat supplied by steam.  Air
for the chemical reactions Is supplied by a power—recovery compressor after
passing through an air filter.  Ammonia is vaporized and oxidized with air to
nitric oxide (NO) at about 689 kPa (100 psl) and 900°C (1.650QF).  The oxida-
tion is accomplished in a converter consisting of a 95 percent platinum and 5
percent rhodium wire gauze.   Compounds leaving the oxidation chamber pass
through an air preheater, a waste heat boiler and a platinum filter (used to
catch any platinum driven out of the converter), before being cooled further
and introduced to the bottom of the absorption tower.  Tail gases from the top
of the tower pass through an entralnment separator to remove acid droplets or
mist, are heated in an exchanger counter to the reaction gases, expanded
through the compressor, and exhausted to the atmosphere.  An alternative  con-
trol system consists of passing the gases from the entrainment separator
through a molecular sieve adsorption bed and on to the reheater and tail  gas
expander prior to discharge to the atmosphere.

Pre-St^artup Operations

     The most Important piece of equipment requiring mechanical checkout  Is the
drive train consisting of a steam or electric-driven turbine, an air compressor,
and a tall gas expander.  Items which must be analyzed in the drive train include
couplings, low, high, and overspeed operation, alignment and balance of rotors
and pistons, synchronization between front and back ends, the lubrication sys-
tem, and all operational turbine trips.   Examples of turbine trips (shutdowns)
which must be evaluated are:
                                     20

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hO
I-1
                                                                                EHTHAIHMENT
                                                                                SEPARATOR
                     TO
                 ATMOSPHERE
TAIL
CASES
 CONDENSED
 STEAM AND
* MAKE UP WATER
                                                                                       NITRIC
                                                                                       ACID PRODUCT
                 Figure 5.  Flow diagram for nitric  acid production by  the pressure process.

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     *    high water level in auction pot,

     *    radial and thrust vibration,

     •    lube oil supply, and

     •    air/ammonia ratio.

Once all of these equipment checks  are performed, the complete unit is dis-
assembled, all parts and bearings are rechecked and oiled, the lubrication
system is drained and flushed, and  the train is reassembled.  A time-consuming
aspect of the drive train checkout  involves plotting of the unit's surge curves.
Once the unit is operational, the air compressor can be used to blow out down-
stream air and steam lines.

     Other equipment debugging procedures are performed according to individual
"punch lists" and are summarized as follows:

     Liquid piping and coded vessels - pressure tested with water at maximum
     working pressure.

     Qaa lines - cannot be checked  until plant is operating,

     Relief valves - bench tested with required pressure^-if serious problems
     exist, they are sent out for repairs.

     Heat: exchangers - flushed with water or a cleaning solution.

     Waste-Heat Boiler - undergoes  a hydrostatic check followed by pretreatment
     with chemicals to prevent corrosion due to oxygen and/or water prior to
     plant startup,  A final procedure before production starts consists of
     filling the boiler with water  and warming with steam to prevent shock to
     the system.

     Absorber column - shipped to the plant as a complete package and can be of
     either a bubble cap or sieve tray arrangement.  The column is prepared by
     flushing with water to clean and check flow and level Indicating instru-
     ments.   Sieve tray columns are more sensitive to gas versus liquid flow
     and may require 1 hr to seal properly whereas a bubble cap unit may take
     about 20 rain.

     Instrumentation - cannot be installed until all other equipment is in place.
     A critical component is the ammonia/air ratio control system which must be
     accurately calibrated to read  concentrations of about 9-11 percent ammonia
     in air.
                                      22

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Startup Qperat ions

     Once all equipment is installed and thoroughly checked for proper
mechanical operation (this may take from 2 tp € months), the plant is ready
to undergo initiation of nitric acid production.  Preliminary startup opera~
tions consist of the following steps:

     1,   startup of air compressor system

     2,   initiation of water flow to adsorber tower and caustic flow
          to, scrubber (where a scrubber Is used)

     3.   platinum gauze lit by hydrogen torch to initiate burning of
          ammonia (flame is self-sustaining)

     4«   Ammonia flow Is begun.

     Within 2 to 3 weeks of this  initial startup, the plant is ready for a test
or demonstration run.   Test runs  usually last 3§ 7,  or 14 days depending on
the contract.   During this time,  the plant must achieve Its peak efficiency,
maximum design rate, and meet all applicable emission regulations.   A violation
of any of these conditions or other equipment malfunctions results  In a cessa-
tion of the test run..  The conclusion of a successful test run results in the
"legal acceptance" of the plant from the contractor.

     The best point in time to define plant startup  is when the ammonia flow
to the converter is initiated.  Barring no unusual problems, the completion of
a successful test run and the achievement of maximum production rate should be
about one month or less from this startup point.  An important point with re-
spect to nitric acid facilities is that the summer months are the most critical
for proper operation due to cooling requirements for the exothermic reaction
involved.   For this reason, most  new plants try to come on line during the
summer when a successful test run would be most meaningful.  Because of the
requirement for performance testing within 180 days  of startup,  It  is conceiv-
able that testing could be required during the winter months when a plant would
find it easiest to meet applicable emission limitations.  In this instance,
regulatory agencies might want to conduct testing as soon after startup a,s
possible, consider postponement of tests until the following summer, or con-
sider winter testing and subsequent summer testing.
                                      23

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                                 REFERENCES
1.   Personal communication with Mr. Bill Ryan, Kaiser Agricultural  Chemicals,
     Savannah, Georgia, March 30, 1979.

2.   Personal communication with Mr. Louis Pebworth, Farmland  Industries, Dodge
     City, Kansas, April 18, 1979.

3.   Personal communication with Mr. Lloyd Thomas, Agrico Chemical Co.,
     Catoosa, Oklahoma, April 18, 1979.

4.   Rosenberg, Harvey S., Molecular Sieve NO,,,. Control Process in Nitric Acid
     Plants.  EPA-600/2-76-015.  January 1979.
                                     24

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                      SULFURIC ACID PLANTS - SUBPART H
                               §60.80 - 60.85
Introduction

     Facilities affected by this regulation are those plants producing sulfuric
acid by the contact process by burning elemental sulfur, alkylatlon acid, hydro-
gen sulfide, organic sulfides and mercaptans, or acid sludge.  Facilities which
convert sulfur dioxide or other sulfur compounds to sulfuric acid primarily as
a means of preventing emissions of the former are not subject to the regulation.
Emissions of gaseous sulfur dioxide cannot exceed 2 kg per metric ton (4.0
Ib/ton) of 100 percent sulfuric acid.  Acid mist emissions, expressed as sul-
furic acid, cannot exceed 0.075 kg per metric ton (0.15 Ib/ton) of 100 percent
acid produced.  Opacity must be less than 10 percent.  In addition, continuous
monitoring for sulfur dioxide is required.  Sources constructed, reconstructed
or modified after August 17, 1971, are subject to the regulations.

Process Description

     Three methods used to manufacture sulfuric acid (I^SO^) are the contact,
spent acid, and metallurgical processes,  Che first two of which are shown
in Figure 6.   Spent acid utilization occurs at petroleum refineries where
the acid is available.   The metallurgical process is employed as a sulfur
dioxide abatement method at plants roasting metallic sulfide ores and for
this reason is not subject to the regulation.

     The most widely used manufacturing method is the contact process, in which
sulfur is burned to produce sulfur dioxide.  Sulfur is transported to the plant
in either the molten or elemental state;  if not shipped in the molten state, the
sulfur is melted and filtered prior to burning.  Combustion air required for
burning is dried with 93 to 98 percent acid in drying towers and then fed to
the sulfur burner.  Before the sulfur dioxide (802)  gas can be Introduced to the
converter, It must be cooled to about 427°C (800°F), the minimum temperature
at which the catalyst (usually diatomaceous earth Impregnated with vanadium
pentoxidc) will hasten the chemical reaction.   Heat  is usually recovered in a
waste heat boiler, where steam is produced, and a heat exchanger, in which sul-
fur trioxide (S03) from the converter passes through and S02 surrounds the ex-
changer tubes.  The S02 gases are purified by filtration prior to introduction
to the converter.   862 is oxidized to 803 in the converter usually in four
stages with most (""75 percent) of the conversion taking place in the first
stage.  The temperatures are critical at  the point of introduction to the next
pass and hot gases are again used to provide heat to other points in the plant.
The 803 can then be absorbed in an oleum tower (for  production of oleums or 803
in ^SOiJ and/or an absorbing tower (for  production  of I^SOi, in water).   The
acids are then cooled and pumped to storage and the  absorbing towers.  Best

                                      25

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             SULFUR MINN ING I
to
         AIR
            *IR FILTER            DRYING TOWER     SULFUR       BOILER
                     COMPRESSOR                 BURNER
            SPENT ACID)
                                                                              SOj
           COMBUSTION BOILCR          \  _ HIST
            CHAMBER       HUMIOIFYHM

                                   MS COOLER
c
(

<



-1
/ ^
CATALYST

CATALYST

CATALYST

CATALYST



*—

pxc.
HEAT
                                                                             «AS   I	

                                                                            coo«-'"«   CATALYTIC
                                                                                     CONVERTER
                                                                                                 EXCHANBER
 1^
        f
                                                                                                                    | MIST '
                                                                                                                    IELIMI-;
                                                                                                                    INATOR !
                                                                                                                             STACK
1'ITERPASS    FINAL
ABSORBING  ABSORBING
  TOWER      TOWER
                                                                                                              r\

                        Figure  6.   Schematic diagram of  two processes for  manufacturing  sulfuric  acid

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demonstrated technology for control of SC>2 emissions is  the dual  absorption
process and for acid mist is the high efficiency mist eliminator.  An  alternate
control system consists of a hydrogen peroxide scrubbing system  (DuPont's
"Tysul" system).

Pre-Startup pperations   •  . -

     Once equipment is delivered to the plant, certain mechanical checks can
be performed prior to final hookups.  Gas and steam piping systems undergo
rigorous pressure testing at..1*5 times their design operating pressure.  The
waste heat boiler undergoes hydrostatic testing according to ASME codes for
fossil fuel-fired pressure vessels., All other acid and water piping are tested
(primarily for leaks) at their normal operating pressure.

     Pumps are rotated to ensure proper operation and blowers may be run for a
day or two to check for balance and vibration.  Lubrication systems would also
be analyzed.              ,1                    ,

     During the final stages of construction, major vessels such as gas to gas
heat exchangers, absorbers,"converter, and sulfur storage tanks are manually
inspected by an experienced startup engineer prior to "closing."  Following
this Inspection procedure,  the plant would be ready to begin the initial
heating of the catalyst.                         :,

     Preparation for catalyst bed heating begins with the initial low  level
firing of the combustion chamber (sulfur burner).  The combustion chamber con-
sists of multiple layers of brickwork which must be heated slowly to about
fl71°C (1,600°F) to eliminate any entrained moisture.  This procedure can take
from 7 to 12 days.

     The waste heat boiler  will then undergo a boilout procedure wherein the
unit is filled with water and degreasing chemicals, warmed, flushed, and
drained, and then has all gaskets replaced and is refilled with normal boiler
water.  Concurrently, the drying and absorbing towers are water-batched for
leak detection followed by?'acid recirculation.

Startup Operations . ;•:•  : -~ "

     Prior to the initial?''feed'.,of raw material, the heating "of the system is
accomplished In three phases totaling about 30 hr.   Phase I consists of an
18-hr period to preheat the furnacej Phase II takes about 2 hr to blow pre-
heated air through;the converter; and Phase III requires 10 hr to reheat
the furnace and thjeh heat the catalyst bed to the Ignition temperature.

     Startup follows the preheating period and is best defined as the  first
time raw material is fed-"tb the system, whether it be sulfur or spent acid
(alkylation chemical,, riitration sludge and hydrogen sulf ide) .   The raw material
feed is begun at aboug:Z5 percent of the design rate and is gradually brought
up to full load depending on the .proper functioning of all other plant com-
ponents.  If there are no difficulties, full production rate can be achieved
in 24 to 72 hr.  The moat common problem which results in plant shutdown
is gaa leakage in some part of the system and this will usually occur  in
1/3 of new plant startups,

                                      27

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                                 REFERENCES
1.   Personal communication with Mr. Tony Corey, Monsanto Co., Everett,
     Massachusetts, April 4, 1979.

2.   Personal communication with Mr. Robert Grendel, Monsanto Envlro-Chem,
     St. Louis, Missouri, April 9, 1979.

3.   Personal communication with Mr. Edward Watts, E. I. DuPont Co., Cleveland,
     Ohio, April 21, 1979.

4.   Calvin, E. L.  and F. D. Kodras.  Inspection Manual for the Enforcement of
     New Source Performance Standards as Applied to Contact Catalyst Sulfuric
     Acid Plants.   EPA-340/1-77-008, May 1977.

5.   Drabkin, Marvin and Kathryn J. Brooks.  A Review of Standards of Per-
     formance for New Stationary Sources - Sulfuric Acid Plants.  EPA-450/
     3-79-003, January 1979.
                                      28

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                     ASPHALT CONCRETE PLANTS - SUBPART I
                              §60.90 - 60.93
Introduction

     The facilities affected Under this subpart are those which comprise an
asphalt concrete plant, Which is tided to manufacture asphalt concrete by heat-
Ing and drying aggregate and mixing with asphalt cements.  An asphalt concrete
plant is comprised of any combination of the following:  dryers, systems for
screening, handling, storing, and Weighing hot aggregate; systems for loading,
transferring, and storing mineral filler; systems for mixing asphalt concrete;
and the loading, transfer, and storage systems associated with emission con-
trol systems.

     Affected facilities which commence construction, reconstruction or modifi-
cation nftet June 11, 1973, are subject to the requirements of this subpart.
Those requirements state that no owner or operator of an asphalt concrete
plant shall discharge or cause the discharge into the atmosphere from any
affected facility any gases which;

     1*   Contain particulate matter in excess of 90 mg/dscm
          (0.04 gr/dscf),

     2.   Exhibit 20 percent opacity or greater.

ProceBH bescriptiori

     Asplialt concrete plants are generally classified as a widespread jobbing
operation.  A large majority of the plants operate on a seasonal basis, nor-
mally during the warm months of the year.   Within the industry there are
portable and permanerit plants.   Most of1 the plants are of the permanent type,
primarily located in or around  urban areas were there is a constant market for
their product.   Pdrtable plants are generally moved to the Job site of large
construction projects.  Plant operations at a portable source tend to be more
sporadic than permanent plants  because they depend on work at a field site.
Permanent plants tend to produce most of their asphalt concrete for Federal,
state and local hlghWay departments.

     The rnw materials used in an asphalt batch plant are the aggregate,
asphalt cenient, and possibly mineral filler.   Paving mlxe's are produced for
different uses  with correspondingly different characteristics, which are
primarily determined by the aggregate size distribution.  The three main
distributions are coarse aggregate (retained  on No.  8 mesh sieve),  fine ag-
gregate (passing through a No.  8 mesh sieve), and mineral dust (passing through
a No.  200 mesh  sieve).  The coarse aggregate  can  be as large as  6.4 cm (2%  in.)  in

                                      29

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diameter.   It  consists  of  crushed  stone,  slag,  gravel,  and naturally fractured
aggregate.   Fine  aggregate is  usually  natural sand.   Mineral dust is a filler
used  in  special applications.   It  consists  of finely ground particles of crushed
rock,  limestone,  hydrated  lime,  or Portland cement.   Asphalt cement is mixed
to about 7  percent by weight,  depending upon the  desired characteristics of
the final product.  Asphalt  cement is  manufactured  from crude petroleum and
is seinisolid at ambient conditions.  Consequently,  it is heated to 135° to
163°C  (275°  to 325°F) to facilitate pumping and mixing.   Asphalt cement is
graded based on an industrial  classification and/or  its penetration.

     A schematic  diagram outlining the operations of an asphalt concrete plant
is presented in Figure  7.   In  general, the  preparation  of asphalt concrete
involves hauling  the aggregate from on-site storage  piles and placing it in
designated  surge  bins.   The  material is then metered onto a conveyor belt and/
or bucket elevator which feeds  the aggregate into a  gas  or oil-fired rotary
dryer.   As  it  leaves the dryer,  the  hot material drops  into a bucket elevator
and is transferred to a set  of vibrating  screens where  it is classified by
size and distributed to designated storage,hoppers.   Depending on the product
required, various amounts  of the "sized aggregate are weighed and then charged
into a mixer, usually a pugmill,   The  dry aggregate  is  mixed for a short
period of time to produce  a  homogenous blend.   Asphalt  cement is then pumped
from heated  storage tanks, weighed  and injected into the mixer.   Once the
aggregate has  been uniformly coated  with  gsphaltt; the product may either be
dropped  into an awaiting truck or  transferred to a storage silo and sub-
sequently loaded  onto a truck.   The  former  operation is  typical of a batch
plant whereas the latter represents .a  continuous operation.   Particulate
emissions generated during the  process are  typically controlled  by a mechanical
collector followed in series with,a baghouse or wet  scrubber.   Because  the
physical size of a plant is  relatively small, one air pollution  control system
is all that is normally  required to  treat process emissions.

     The equipment used  for'asphalt  production  differs  from plant to plant.
Conveyors can be used interchangeably  with  bucket elevators;  storage bins
can be arranged differently, 0r,replaceil ^altogether  with  open  pile  storage.
The moot critical piece  of equipment from the standpoint  of  emission abatement
is the rotary dryer.  The counter-current design is  the most popular.   It is
basically n rotating cylinder which is  horizontally  inclined with  a  burner
near the axis at the depresse'd end  arid;an aggregate  feeder at  the  elevated end.
The aggregate flow is toward the burner rflaine and opposed  to the  burner  com-
bustion gas flow.   Often internal flights  are used for agitation.  Commonly,
the temperature in a dryer is 121  to,,232  C  (250°  to 450°E), the gas  stream
velocity is 2.3 to 4.1 m/sec (450 to 800, ft/min),  and the volumetric  flow rate
is 33,980 to 118,931 m3/hr (20;;000  to 70,000 acfm).   During normal startups,
the air  in the control equipment is warmed sufficiently, before production  is
started;  this is particularly important for baghouses.'-  Similarly, the blower
or fan is always running before the dryer  burner is-  fired and  after  the  cold
feed material or burner and dryer are turned off.

     Rotary dryers employed solely  for  the purpose of drying aggregate have
been used extensively in the past.   However, since the early 70's drum mixers
have become more widely used.  The  drum mixer serves the same  function as  the


                                     30

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EMISSIONS
                                    PRIMARY DUST COLLECTOR
                                                        SEALED
                                                        OVERFLOW
                                                          BIN
                                                                     ASPHALT!
                                                                          TANK
   Figure 7.   Schematic diagram of a typical batch asphalt concrete plant.

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rotary dryer, but also functions as the aggregate-asphalt cement mixer.  Graded
aggregate is metered Into the front half section of the inclined drum mixer
where it is dried.employing gas or oil-fired burners.  AB the mixer rotates,
the dried aggregate flows around a steel plate which separates the drying end
of the drum from the asphalt mixing end.  As the aggregate flows into the back
half section of the drum, asphalt cement is injected beginning the production
of asphalt concrete.  Flights, mounted in both ends of the drum, facilitate
drying and mixing.   Once thoroughly blended, the asphalt concrete is trans-
ferred by a slat conveyor to storage silos prior to truck loadout.  Drum mixers
are associated with continuous operations.

Pre-StartupOperations

     Once the physical plant structure has been erected, various pre-startup
checks are made prior to the production of asphalt concrete.  The first step
is to connect and test (including calibration) all electrical systems, asso-
ciated instrumentation and control panels.  Once this has been completed,
conveyor belts, bucket elevators and vibrating screens are checked for align-
ment, rotation and free clearance.  Process equipment and air pollution equip-
ment are checked for hydraulic and dust leaks.

     The aggregate dryer is usually seasoned before it is put into continuous
operation under design conditions.  During this period, the burners are
operated under low fire and a limited amount of aggregate is fed into the
dryer.  The aggregate is fed into the rotating dryer to absorb some of the
heat which protects new parts and control equipment (especially a baghouse)
from exposure to high temperatures.  If a baghouse is the primary control
device, it is during this phase when the initial dust cake forms on the fabric
filters, conditioning the bags for normal continuous use.  Seasoning of the
dryer will last from 10 to 40 hours.  After the dryer has cooled down it is
inspected for proper expansion, rotation and alignment.

     Typically, plant operators will conduct a trial run with dry aggregate to
assure that the conveyor belt feed rate and distribution system are functioning
properly; the aggregate dryer is working; and bucket elevators, sizing screens,
and mixer are all operational.   During this period, the asphalt cement storage
and distribution system is also checked.  The pre-startup shakedown operations
will last approximately 3 weeks.   There are relatively few differences in the
pre-startup operations and time required for shakedown between batch and con-
tinuous operation plants and permanent and portable plants.

     Portable plants, which are moved from one job site to another either
beforej during or after the production season, require about 1/3 to 1/2 the
amount of time for startup as for its initial original startup (i.e.,  1 to
2 weeks).  To minimize problems associated with relocation,  the plant  is re-
erected in the same configuration as it was at the previous  site.   This as-
sures continuity and reduces the number of components which have to be re-
constructed, particularly pipe fittings and connections.
                                     32

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S t ar tup Operations

     Hie initial plant startup is considered to be when asphalt cement is first
mixed with the dried aggregate.  As indicated previously, this will occur ap-
proximately 3 weeks after the plant has been physically erected.  Various ad-
justments and recalibrations are made after the plant has been started up to
fine tune process operations.

     Once the production of asphalt concrete has commenced, it may take any-
where from only a day or two to 2 months for a plant to achieve its maximum
production rate.

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                                  REFERENCES
1.    Background Information for New Source Performance Standards:  Asphalt
     Concrete Plants.  February 1974.  U.S. Environmental Protection Agency,
     Research triangle Park, North Carolina.  EPA-450/2-74-003.

2.    Inspection Manual for Enforcement of New Source Performance Standards:
     Asphalt Concrete Plants.   June 1975.  U.S. Environmental Protection
     Agency, Division of Stationary Source Enforcement, Washington, D.C.

3.    Standards of Performance for Asphalt Concrete Plants, Subpart I,
     Environment Reporter, April 1979, p. 121:1521.

4.    IGCI Air Pollution Control Technology and Costs in Nine Selected Areas,
     September 1971*, APTD-1555.

5.    Air Pollution Engineering Manual, May 1973.   AP-40, Second Edition.
     U.S. Environmental Protection Agency, Research Triangle Park, North
     Carolina.

6.    Personal communication with a representative of the National Asphalt
     Pavement Association, Riverdale, Maryland.  May-22, 1979.

7.    Personal communication with Mr.  Hans Goering, Barber Greene Company,
     Aurora, Illindis.   May 22, 1979.

8.    Personal communication with Mr.  Joseph Laird, Maryland State Asphalt
     Association,  Baltimore, Maryland, May 30,  1979.

9.    Personal communication with Mr.  Joseph Munsil, Cedar Rapids Equipment ,
     Company, towa Manufacturing Company, Cedar Rapids, Iowa.   May 30,  1979.

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                       PETROLEUM REFINERIES - SUBPART J
                               §60.100 - 60.106
Introduction

     The NSPS for this category is applicable to the following facilities
within petroleum refineries:

     1.   fluid catalytic cracking (FCC) unit catalyst regenerators

     2.   fuel gas combustion devices

     3.   Claus aulfur recovery plants except those of 20.3 metric ton/day
          (20 long ton/day) or less.

     Since each of these processes and the performance standards pertaining to
them are different,  the following sections discuss each one individually:

A.   jyai^Jjata.lj^tic Cracking (FCC) Unit Catalyst Regenerators

     Performance standards were promulgated for particulate matter (not to
exceed 1.0 kg/1000 kg or 1.0 lb/1000 lb of coke burn-off), opacity (30 percent
maximum, except for one 6-minute average opacity reading in any 1 hour period),
and carbon monoxide (not to exceed 0.05 percent by volume).  Where gases from
the FCC regenerator pass through an incinerator or waste heat boiler in which
auxiliary or supplemental liquid or solid fossil fuel is burned, the incre-
mental rate of particulate matter emissions cannot exceed 43.0 g/MJ (0.1C
lb/106 Btn) of heat input attributable to the fossil fuel used.  Continuous
monitoring IB required for opacity and carbon monoxide.  Sources constructed,
reconstructed or modified after June 11, 1973, are subject to the regulations.

     Process Description

     Catalytic cracking is a high-temperature, low-pressure process that con-
verts certain heavier portions of crude oil into gases, gasoline blend stocks,
and distillate fuels.   A fluid catalytic cracking unit is composed of two
basic sections; reactor and, regenerator.  The cracking reactions take place
continuously in the cracking section, with the spent catalyst oeing continuous-
ly regenerated and returned to the reactor.  Both the cracking and regeneration
sections operate on the fluidization principle, which makes possible a contin-
uous flow of catalyst as well as hydrocarbon feed.   Regeneration of the catalyst
is necessary due to  metal contamination and poisoning or deposits that coat the
catalyst surfaces and thus reduce the area available for contact with the re-
actants.  Figure 8 presents a flow diagram of the catalytic cracking process.


                                      35

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PRODUCTS
FLUE 6*3
           REACTOR
                                                REGENERATOR
                                                      REGENERATED
                                                      CATALYST
                                                       SLIDE
                                                       VALVE
                                             FEED
                                        PREHEATER
                                           FUEL
                                                                            HEATER
                Figure 8.  Flow diagram for catalytic cracking process.

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      Pre-Startup  Operat ions

      Prior  to startup, certain  operations  are  performed  to  ready the FCC for
 service.  These preliminary  activities  are necessary  to  help  insure a smooth
 and orderly startup of the operating  processes.   Some of the  pre-startup
 activities  include:

      1.   General mechanical checkout of equipment.   This includes  pumps
          and other material handling equipment.

      2.   Instrument System  Review.   This  includes continuity checkouts
          aa well as calibration of all transmitters,  transducers and  control
          valves.                                     ......

      3.   Pressure testing of welds and a  general washout of equipment
          With air, nitrogen  or water.                 ,,,           - /'

      4.   Slow warmup of equipment to dry,  out refractories and 'minimize
          the possibility of  thermal  shocks.

      This curing of the refractories  is done slowly and  can take place over
a number of days depending on the quantity of material involved.

      Startup Operations

      After the refractories are dried out  and conditioned, the next procedure
is to load and circulate the catalyst.  Once the catalyst is circulating, it is
heated by means of an air heater.  At this point, feed can be introduced to  the
FCC unit.  The date of this introduction of feed to the FCC unit can be  defined
as the date of startup.

B.    Fuel Gas Combustion Devices

      Performance standards were promulgated for sulfur dioxide based on  either
a limit on hydrogen sulfide (not to exceed 230 mg/dscm or 0.10 gr/dscf)  in the
fuel  gas or an equally effective control of sulfur dioxide emissions.  In addi-
tion,  there is the requirement either for continuous monitoring of sulfur diox-
ide in the gases discharged to the atmosphere from the combustion of fuel gases
or for continuous monitoring and recording of the concentration of hydrogen
sulfide in fuel gases burned in any fuel gas  combustion device*  Sources con-
structed, reconstructed  or modified after June 11, 1973,  are subject to  the
regulations.

     Process Description

     A fuel  gas  combustion device is defined  as any piece of equipment» such
as process heaters,  boil-ers and  flares used to combust fuel  gas, but does; not
include facilities in which gases are combusted to produce sulfur or sulfuric
acid.   Flare combustion of process upset gas  or fuel gas  which is released to
the flare as a result  of  leakage from a relief valve is exempt.
                                      37

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     Pre-Startup Operations

     Aa discussed previously, preparation of process equipment involves
primarily a mechanical and instrument checkout.

     Startup Operations

     Startup of fuel gas combustion devices is initiated with a test firing.
Further information on procedures for startup of combustion devices can be
found in the discussion of boiler startup (Subpart D).

C.   Glaus SulfurRecovery plants

     Emissions of sulfur dioxide (S02) are limited to 0.025 percent by volume
at 0 percent oxygen (dry basis) if emissions are controlled by an oxidation
system or a reduction control system followed by incineration; or 0.030 percent
by volume of reduced sulfur compounds and 0.0010 percent by volume of hydrogen
sulfide (HZS) calculated as S02 at 0 percent oxygen (dry basis) if emissions
are controlled by a reduction control system not followed by incineration.
Continuous monitoring and recording of SC>2 in the gases discharged to the atmos-
phere is required if an oxidation or reduction control system followed by in-
cineration is used.   Continuous monitoring and recording of H2S and reduced
sulfur compounds in discharged gases is required if a reduction control system
not followed by incineration is used.  Sources constructed, reconstructed or
modified after October 4, 1976 are subject to the regulation,

     Process Description

     A Glaus sulfur recovery plant is a process unit which recovers elemental
sulfur from hydrogen sulfide by a vapor-phase catalytic reaction of sulfur
dioxide and hydrogen sulfide.  A typical three-stage Glaus unit designed to
operate on a "standard" acid gas rich in hydrogen aulfide is shown in Figure 9.

     Pre-Startup Operations

     As discussed previously for the FCC process unit,  preparation of process
equipment involves the following activities;

      1.   general mechanical checkout (pumps,  etc.)

      2,   instrument checkout

     3.    confirmation of "as-built" conditions with design specifications

     4.    pressure testing of welds

     5,    acidize  compressor lines

     6.    general  washout (air,  nitrogen,  or water):

     ?.    commission utilities
                                      38

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            ACID
            SAS
SO
                   HO
                   DRUM
                T
               WATER
KiSH PRESSURE
STEAM
f
Iff
^


t


t




— i i
- ' RCftCTIQW "i
- , FURNACE J
F" ' '
f
. BOILER FEED
WATER

^






>
~1





BOILER
^V)— E
AIR BLOWER

i

•i
j



>

i
J
(COWVERTEH \
.0.. )

" RE HEATER
NO,!
t



W PRES-
S UREA STEAM
CONDENSE*


NO. t
f
CEED WATER
1*

]
H
\



























•\



rt
i



t


'
(CONVERTER ]
KQ.Z /

REHEATER
NO.Z
(



LOW racs-
•UMC&STEAI
T
CONDENSER
NO, I
f
BOILER FEED
WATER
t
i





















1-1



'

<



rt
1




f C

REHEATER
NQ.S
i



LOW PRES-
SuftEiSTEAH
f T
CONDENSER
'.NO.}
f
•OILER FEED
WATER
1
t










h
                                                                     SULFER PIT
                                                                                                iRTER  \

                                                                                                >•*    J
CONVERTER
   MO
      LOW  l»RES-_

    j      TiTliJ
                                                                                                             TAIL CAS
      CONDENSE*
        NO. 4
                                                                                                 BOILER FEED
                                                                                                   WATER
                                                                                                         1
                                                                                                       LIOUID
                                                                                                •ULFER
                                                                                                mm*
                 Figure  9,  Flow diagram for a. typical three-stage claus sulfur  recovery plant3.

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      8,   dry out refractories (slow warinup)

      9.   load catalyst

     Startup Operations '

     Startup for Glaus sulfur recovery plants can be defined as the Introduc-
tion of feed to the unit.  Once feed Is Introduced, additional checks  for leaks
are performed.  If no leaks are detected, process variables are aimed  at test
conditions previously determined.
                                     40

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                                 REFERENCES
1.   Personal communication with Mr. Michael Volker, Ashland Oil Refining,
     Ashland, Kentucky.   March 7, 1979.

2.   "Chemical Process Industries" fourth edition, Shreve and Brisk, McGraw-
     Hill Book Company,  New York, 1977.

3.   Chute, Andrew E,   Tailor Sulfur Plants to Unusual Conditions.  Hydro-
     carbons Processing, April 1977, pp. 119-124.
                                      41

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              STORAGE VESSELS FOR PETROLEUM LIQUIDS - SUBPART K
                              §60.110 - 60.113
Int ro d uc ti cm

     The provisions of Subpart K of 40 CFR 60 dictate .performance standards
for storage vessels for petroleum liquids,  Subject to the requirements of
Subpart K are storage vessels with capacities greater than 151 m  (40,000 gal),
but not exceeding 246 m3 (65,000 gal), which have commenced construction, re-
construction or modification after March 8, 1974.  In addition, those storage
vessels having a capacity greater than 246 m3 (65,000 gal) and having commenced
construction, reconstruction or modification after June 1.1, 1973, are subject
to Subpart K.  If the true vapor pressure of the petroleum liquid, as stored,
is equal to or greater than 10.3 kPa (1.5 psia) but not greater than 76.5 kPa
(11,1 psia), the storage vessel must be equipped with a floating roof, a vapor
recovery system or their equivalents.  If the true .vapor pressure is greater
than 76.5 kPa (11.1 psia), the storage vessel must be equipped with a vapor
recovery system or its equivalent.

     The owner or operator of a storage vessel is required to maintain a file
of each type of petroleum liquid stored, Reid vapor pressure, dates of storage
and date on which the storage tank is emptied.  In addition, the owner or
operator shall record average monthly temperature and true vapor pressure.  No
performance testing is required for petroleum storage vessels.

IProc es s jDeg crip t ion

     There are two types of petroleum storage tank emission reduction systems
presently being used:  floating roof and vapor recovery.

     Floating roof storage tanks are used for storing volatile material with
vapor pressure in the lower explosive ranges minimizing fires or explosive
hazards.  There are three types of floating roof tanks:  pan, pontoon and
double deck.  The pan floating roof type has been used for the past 40 years
and is now being phased out.   Many operators have had tilting and sinking
problems with this type of roof; besides, the pan roof also has a high vapor-
ization loss around the periphery of the roof.  The pontoon roof Is mainly
used on tanks with larger diameters and provides for better stability.
Some pontoon roofs have a center drain with hinged or flexible connections for
roof drainage problems.  In addition, traps or dams are provided on the under-
side of the roof.   The traps  retain any vapors formed as  a result of localized
solar boiling.   The double deck floating roof, which is the most expensive,
reduces the effect of solar boiling and has more rigidity than the pan and
                                      42

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pontoon floating roofs.  Double deck roofs have corapartmented dead-air spaces
over the entire liquid surface.  The roof also has drains for water accumulation
and vapor traps on the underside of the roof.

     A vapor recovery system is designed to handle vapors originating from
filling operations.  The recovered vapors are compressed and charged to an
absorption unit for recovery of condensable hydrocarbons.  The system includes
vapor lines Interconnecting the vapor spaces of the tanks that the system
serves.  Each tank should be capable of being isolated from the system.  Tank
isolation and operation is by manual and pressure controlled butterfly-valves,
regulators, and check valves.  Knockout pots are normally used at low points
in the vapor line to remove condensate.  Noncondensable vapors are piped to a
fuel gas system or to a smokeless flare.  When absorption of the condensable
vapors is not practical from an economic standpoint,  these vapors, too,  are
either sent directly to a fuel system or incinerated  in a smokeless flare.

Startup Operations

     Since no performance testing is required for petroleum storage vessels,
the 180 day test period does not apply in this case.   However, the proper
operation of either the floating roof and/or vapor recovery system is essential
for the minimization of hydrocarbon emissions.  Storage vessel systems are in-
spected and checked for structural, mechanical,  electrical and hydraulic prob-
lems.   The primary checks for the petroleum storage vessel are water pressure
tests  for structural defects and mechanical operation and clearances of the
storage vessel's roof and seals, compressors and vapor control valves and
actuators.

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                     SECONDARY LEAD SMELTING - SUBPART L
                              §60.120 - 60.123
Introduction

     •fhe NSPS for this category,is applicable to the following facilities in
Secondary lead, smelters:  pot furnaces of more than 250 kg  (550 lb) charging
capacity, blast (cupola) furnaces, and reverberatory furnaces.  Performance
standards tor blast (cupola) or reverberatory furnaces were promulgated for
partlculate, matter and opacity.  Particulate matter cannot exceed 50 mg/dscm
(0,022 gr/dscf).  Opacity must be less than 20 percent.  Performance standards
for pot. furnaces were promulgated for opacity only, which must be less than
10 percent.  Sources constructed, reconstructed or modified after June 11, 1973,
are subject to the regulations.

Process Description

     The processing of secondary lead centers around the utilization of three
furnaces.  Smelting operations on the scrap lead are carried out in the blast
(cupola) furnace and/or reverberatory furna.ce and the final purification steps
in pot furnaces.  ,

     The blast (cupola) furnace used in processing secondary lead is similar
to those in the ferrous industry; cylindrically shaped and standing vertically.
Forced air, sometimes oxygen enriched, is introduced near the bottom of the
furnace.  The furnace is batch fed at the top.  A typical charge is made up
of about 80 percent scrap lead (generally battery plates and including 8 per-
cent return slag)  8 percent coke, 2 percent iron, and 10 percent limestone.
Heat la produced by the combustion of the coke which also provides an atmosphere
for reducing the lead oxide feed.  The lead metal collects at the bottom of
the furnace and is customarily drawn off through a tap hole.

     Reverberatory furnaces operate by radiating heat from the gas or oil fired
burners and the surrounding hot refractory lining onto the contents of the
furnace.  The flame and products of combustion come in direct contact with the
charge material.  The furnace is commonly rectangular in shape with a shallow
hearth and constructed of fire brick and refractory materials.  The principal
use of the reverberatory furnace involves the melting and purification of
lead by removal of extraneous ingredients.

     The reverberatory furnace may be charged with molten lead from the cupola
  . a continuous basis.  In this case, air is blown through the bath either
  ntinuously or intermittently to oxidize metal impurities.   The metal dross,
wnlch is formed, floats on top of the lead and is removed intermittently by


                                      44

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slagging.  The lead product is tapped from the furnace into molds on an
Intermittent basis.  If lead oxide drosses are charged to the furnace, a
reducing agent such as granular carbon must be added to the bath to reduce
the lead oxide to metallic lead.  The furnace operates at about 1260°C
(2300°F) principally to allow the reaction between Metallic impurities and
the oxygen sparged Into the bath.  The high temperature also allows for
afterburning in the furnace proper.  This Is accomplished by Maintaining a
tifeiit furnace, that is, excessive air leakage into the furnace Is prevented
and the amount of oxygen introduced to the furnace Is thus controlled.  The
reverberatory furnace product Is a semi-soft lead which is more pure than
that which the blast furnace produces.

     Pot furnaces are used for remelting and for final alloying and refining
processes before pouring into product molds.  They are open-top, ceramic-lined
kettles, hemlspherlcally shaped and generally range in size from 0.9 to 45
metric ton (1 to 50 ton) capacity.  They are normally under-fired by natural
gas burners.  Refining is a batch operation that can vary from several hours
to two qr more days, depending on the required final composition.  Dressing
agents or alloys are generally added individually and the bath is normally
agitated or, in some cases, air is bubbled through the bath.  Drosses are
normally skimmed off the surface of the lead by hand.

     Partlculate matter is typically controlled by fabric filters in secondary
lead smelting operations.

Pre-startup Operations

     Prior to startup, certain operations are undertaken to ready the furnace
for production.  These preliminary activities are concerned not only with the
operation of the furnace but also with the operation of material handling
systems, and air pollution control systems.

     For the furnace, some of the operations which are considered In the
pre-startup category Include;

     1.  Delivery, assembly and hook-up of utilities

     2.  Installation of pollution control equipment

     3.  Installation of air handling system including stack

     4,  Check out of wiring and control systems

     5.  Installation of refractory

     These activities will typically require 1 month to complete.

     Related to the operation of the furnace and crucial to achieving maximum
production arc the start-up of material handling systems and the air pollution
control systems.  Problems in either of these two areas can cause delays of
several months in preventing a smelting operation from achieving design
capacitlcK.

                                   45

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     In efforts to reduce worker exposures  to  lead,  some new installations
of secondary smelting may utilize completely enclosed, remote controlled
operations.  In these cases, debugging the new technology of remote  control
material handling may require several months.

Stgrttig Ogerat ions

    "1
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                                  REFERENCES
1.   Personal communication with Mr. Hess, U.S. Smelting Furnace Company,
     Bellville, Illinois, March 9, 1979.

2.   Personal communication with Mr. Borell, Gould Inc., Industrial Battery
     Division, Sun Valley, California, March 13, 1979.

3.   Personal coramuncation with Mr. Pike, General Battery Corp., Reading,
     Pennsylvania, March 15, 1979.

4,   Personal communication with Warrick Furnace, Chicago, Illinois,
     April 24, 1979.

5.   Personal communication with Steve Haulier, AMAX Lead/Homestake,
     Buick Mine, Missouri, April 10, 1979.
                                      47

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       SECONDARY BRASS AND BRONZE INGOT PRODUCTION PLANTS -  SUBPART M
                               §60.130 - 60.133
 Introduction


     The NSPS for this category applies to reverberatory and electric  furnaces
 of 1,000 kg (2,205 Ib) or greater production capacity and blast  (cupola)  fur-
 naces of 250 kg/hr (550 Ib/hr) or greater production capacity.   For reverbera-
 tory furnaces, the standard limits particulate discharge to 50 mg/dscm (0.022
 gr^dscf) and opacity to less than 20 percent.  Blast (cupola) or electric
 furnaces are governed only by an opacity standard, which must be less  than
 10 percent.  All facilities that commenced construction, were modified or re-
 constructed after June 11, 1973,, are subject to the regulations.

 Process Description

     Brass and bronze ingots are produced from three types of furnaces -
 rcverberatory, rotary and crucible.  In the industry, 95 percent of the ingots
 are produced by direct oil or gas fired reverberatory furnaces.  Rotary fur-
 naces arc also classified as reverberatory units for the purpose of NSPS.  Due
 to the overwhelming predominance in the industry of these units, and the lower
 particulate emissions associated with electric furnace use, only reverberatory
 furnaces are required to meet a mass particulate emission unit.  Figure 10
 presents a schematic of a typical ingot production facility.

     Processing begins with raw materials which consist of copper bearing scrap
 including faucets, telephone or electric cable, radiators and brass turnings.
 Before blending in a furnace, the scrap is preprocessed to remove impurities
 and to concentrate like alloys.  Pretreatment operations take on several forms.
 Mechanical methods include hand sorting of scrap into piles of like material,
 stripping or shredding of wire covering or insulation, magnetizing of  iron
 particles to remove them, and briquetting for size reduction.  Pyrometallurgical
 (heating) methods include sweating of scrap to remove low melting point metals,
 burning to remove wire insulation, drying in a rotary kiln to vaporize  cutting
 fluids on machine shop scrap, and use of a blast furnace or cupola.  Of these
 operations, only the blast furnace (cupola) is governed by NSPS.

     The blast furnace operation is a continuous process that accepts slag
          and  other metal oxides which are byproducts of the ingot produc-
 tion furnaces.   Coke,  copper oxides and other materials are charged into the
 top of the furnace and combustion air,  sometimes enriched with oxygen,  is
blown In through  tuyeres  at  the bottom.   The coke acts  as both a fuel and  a
reducing agent  through the production of carbon monoxide.   The reducing

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*-
10
       (?) = f«USIDN PfltlllS
ICVEtlftltOK

flllNICf
tuciiie
HUCIILE FUMIICE
                             Figure 10.   Brass  and bronze ingot production  facility.5

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 atmosphere allows direct reduction of metallic  oxides  and  the  resultant
 dense molten metal settles from Che nonmetallic glass-like slag.   The  metal
 (black copper) is drawn off for further refining  in  the  ingot  production
 furnaces.

     The reverberatory furnace is commonly rectangular in  shape with a shallow
 hearth and constructed of fire brick and refractory  materials.  The  furnace
 operates by radiating heat from the gas or oil-fired burners and  the surround-
 ing hot refractory lining onto the contents of  the furnace.  The  flame and
 products of combustion come in direct contact with the charge  material.   There
 are five distinct steps in producing brass or bronze of  the desired  specifica-
 tion in a furnace.  First, the scrap materials  are charged into the  preheated
 furnace (charging) and, second, oil or gas is fired  directly into the  charge
 to melt the materials (melting).  The charge is next brought to the  desired
 temperature and fluxes are added to remove impurities  such as  carbon,  metal
 oxides, gases, etc. (refining or smelting).  Fourth, after the impurities are
 removed, metal is added to bring the alloy to the proper metallic composition
 (alloying).  Finally, when analysis indicates the correct  grade has  been
 achieved and the melt is at the proper temperature,  the  metal  is  poured  into
 ingots (pouring).

     The electric crucible furnace follows a similar production sequence.
 Heat, however, is applied indirectly using high or low frequency  induction
 heaters to raise the crucible temperature.  The absence  of direct flame  con-
 tact on the metal minimizes metallic volatilization  and  thereby reduces
 particulate generation.

     Particulate emissions vary with the content of  the  alloy being  produced
 and the presence of impurities in the scrap feed.  Most  of  the particulate
 emissions are metal oxides, predominantly zinc  oxides  (45  to 77 percent)  and
 lead oxides (1 to 13 percent).  Fabric filters  are extensively used  to control
 emissions from all three types of furnaces^ although electrostatic precipitators
 have recently been adopted as  well.

     For various reasons, including the promulgation of  an  NSPS for  this  industry,
 only one new plant has been constructed in the  country since 1973.   Total ingot
 production has remained relatively stable during this period, and producers have
 consolidated operations to the point where only 30 ingot manufacturers are now
 in operation.

 Pre-Startup Operations

     There are numerous  material handling subsystems in  a  secondary  brass and
 bronze ingot production facility that must be individually  tested before  ingots
 are poured.   The number and types of these systems is entirely dependent upon
 specific plant practice.   Virtually  all facilities will have a sorting/
 classification process for the incoming scrap,  a magnetizing station for re-
 moval of ferrous metals  and a  briquetting operation to facilitate furnace
 charging.   These subsystems incorporate cranes,  conveyors,  pulleys, motors,
hydraulic presses,  etc.,  all of which must be operated; before startup.   Less
 common pretreatments  such as wire stripping,  shredding, sweating,  burning and
use of cupolas can  be  installed,  although they  are finding less favor in the


                                     50                     .

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industry due to economic and environmental reasons and increased reliance on
large scrap dealers who will clean and process raw scrap.  Air pollution con-
trol devices, typically baghouses, must be opetated to insure proper installa-
tion and structural integrity of all ductwork, housings and supports.  Finally,
the furnace(s) must be inspected for proper refractory installation (all units),
freedom of rotation (rotary units, tilting reverberatory and electrical units)
and correct charging clearances.  Pretreatment (curing) of furnace refractory
is Cj-tional and left to the discretion of the plant operator.  When practiced,
curing typically takes 2 to 3 days.  Electric induction furnace equipment
(transformers, rectifiers, etc.) is also energized prior to startup.  Complete
checkout of this equipment necessarily requires actual plant startup.  Plant
construction typically takes 6-12 months, and individual pre-startup checks
will be performed immediately after the specific piece of equipment is installed.

Startup Operations

     Startup of a new or modified brass and bronze ingot production facility Is
the first day metal is charged Into the furnace and melting begins.  Application
of heat, either directly or indirectly, will cause generation of metallic fumes,
which are the pollutant of concern.  This startup date can be obtained by check-
ing plant production records.   Immediately prior to metal charging and light-off,
the collection equipment is activated to insure particulate emissions are con-
trolled at all times.   When baghouses are used, activation may also Include in-
jecting lime Into the flue gas stream to neutralize acids and prolong bag life.
As the operation of conventional design furnaces is straightforward, most op-
erators will fully charge the unit with scrap and attempt to reach maximum
production as soon as possible.   Under these conditions mechanical and electri-
cal problems will appear and be  corrected immediately.  Furnaces with new designs,
although infrequently installed, will require a slower break-in period to Insure
all metallurgical conditions are correct and the furnace Is operating as designed.
Regardless of furnace type, industry contacts indicated that the 180-day test
time frame could be met by all plants.
                                     51

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                                 REFERENCES
1.   Personal communication with Mr. Drickenmiller, American Brass Company,
     Dothan, Alabama.  May 9, 1979.

2.   Personal communication with Mr. Pinsof, Sipi Metals Corporation, Chicago,
     Illinois.  May 10, 1979.

3.   Personal communication with Mr. Stefinitis, I. Schumann Company, Bedford,
     Ohio.   May 10, 1979.

4.   Personal communication with Mr. Bowman, Brass and Bronze Ingot Institute,
     Chicago, Illinois.  May 14, 1979.

5.   Inspection Manual for Enforcement of New Source Performance Standards:
     Secondary Brass and Bronze Ingot Production Plants.  EPA-340/1-77-003.
     January 1977.
                                      52

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                      IRON AND STEEL PLANTS -  SUBPART N
                               §60.140 - 60.144
 Introduction

     The NSPS for .iron and steel plants applies to the basic oxygen process of
 steel production.  The facility affected under this subpart is the basic oxygen
 process furnace (BOPF) which produces steel by refining a high carbon-content
 charge using a large volume of an oxygen-rich gas.

     The mass emission standard promulgated under this subpart states that
 gases discharged from a BOPF shall not contain particulate matter in excess
 of 50 mg/dscm (0.022 gr/dscf).  In addition, the exhaust gas from a control
 device shall not exhibit an opacity of 10 percent or greater, except that an
 opacity of greater than 10 percent but less than 20 percent may occur once^
 per Bteel production cycle.  Facilities constructed, reconstructed or modified
 after June 11, 1973, are subject to the requirements of this subpart.

 Process De s cr1pjtlo n

     Steelmaking by a BOPF involves the melting, mixing and subsequent refining
 of scrap metal,  molten iron,  and fluxes charged to the vessel by the injection
 of a high volume of an oxygen-rich gas.  Oxygen may be top blown into the
 vessel by a water-cooled retractable lance or bottom blown through a set of
 fixed tuyeres.  The former method is the more common type of BOPF, whereas
 the latter is a  recent process modification specific to the O^ielle-Basic
 Oxygen Process (Q-BOP) furnace.  A simplified flow diagram outlining steel-
 making in a BOPF is presented in Figure 11.

     The oxygen  blow commences immediately following charging and continues
 for a predetermined length of time depending on the grade of steel desired and
 the charge composition.   After the blow, the molten steel is checked to deter-
 mine If the endpoint chemical composition and proper tap temperature have been
 attained.   If the desired temperature has not been reached, oxygen Is reblown
 into the bath until the  proper temperature is reached.  When the melt meets
 the required grade specifications,  the furnace is tapped.  Tapping involves
 rotating the vessel, pouring  the finished steel into a teeming ladle.  After
 tapping, the vessel is rotated back through the vertical and slag (the solid
waste formed during refining) is poured from the furnace into pots located
 below the furnace floor.   Following slagging, the furnace refractory lining
 and tap hole are checked for  wear before another heat is started.

     Typical air pollution control  equipment installed on BOP furnaces include
a primary hood to collect emissions during the oxygen blow and possibly a
 secondary hood and furnace enclosure.to capture charging and tapping emissions.

                                      53

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                         PARTICIPATES
                         WASTE  GASES
                          AND : HEAT
     SCRAP  METAL
     MOLTEN  IRON
     FLUXES
 OXYGEN -RICH -GAS
VESSEL ALLOYING
     ADDITIONS
ALLOY  ADDITIONS
   *
                   STEEL
                                                            SLAG
             Figure 11.  BOPF Steelmaking process  flow diagram.

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Collected fumes are normally vented to an electrostatic precipitator or high
energy wet scrubber.

Pre-Startup Operations

     Pre-Btartup operations of a BOPF include:

     •    conditioning of refractory lining and tap hole

     •    testing of mechanical controls

     •    instrument checks
     •    checking raw material, process gas and coating water distribution lines

     The refractory lining, including the tap hole, must be preheated before
the furnace is put in operation to prolong the life of the lining and to pre-
vent sudden thermal stresses when the furnace is initially charged.  The con-
ditioning period,  which varies with furnace size and type of refractory, typic-
ally lasts up to several weeks.

     Instruments and mechanical equipment are checked to ensure proper opera-
tion and to correct any defects in installation.  The usual time period re-
quired to check equipment varies from 1 to several weeks.

Start-up Operations

     The start-up period (ranging from initial heat until attainment of maximum
production)  will vary in length from 2 days to a year, depending on the type
of furnace,  and production demands.  Even though melt cycles will remain
lengthy at first,  each steel heat will be produced at the rated furnace
capacity.

     Once the furnace and ancillary equipment has been thoroughly checked out
it will take approximately 8 hours to bring the vessel on-line.  The cyclical
nature of the process suggests startup should be defined as the time the furnace
is put into operation for the first steel production cycle.
                                      55

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                                  REFERENCES
1.   Personal communication with Mr. J. Galbreath, Whiting Corporation,
     Harvey, Illinois.  13 March 1979.

2.   Personal communication with Mr. J. Hanley, Pullman-Swindell, Pittsburgh,
     Pennsylvania.  13 March 1979.

3.   Personal communication with Mr. F. Schick, John Mohr and Sons, Chicago,
     Illinois.   13 March 1979.

4.   Personal communication with Mr. B. Moore, Penn Engineering Corporation,
     New Castle,  Pennsylvania.   13 March 1979.

5,   Personal communication with Mr. Bonder, William B. Pollock Company,
     Youngstown,  Ohio.  13 March 1979.

6.   Personal communication with Mr. B. Wolf, Loftus Engineering Corporation,
     Pittsburgh,  Pennsylvania.   13 March 1979.
                                     56

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                     SEWAGE TREATMENT PLANTS - SUBPART 0
                              §60.150 - 60.154
Introduction

     The standard contained in this part applies to sewage sludge incinerators
that combust wastes containing more than 10 percent sewage sludge (dry basis)
produced by municipal sewage treatment plants or that charge more than 1000 kg
(2205 Ibs) per day (dry basis) of municipal sewage sludge.  Particulate emis-
sions are not to exceed 0.65 g/kg (1.3 Ibs/ton), based on dry sludge input,
and opacity is limited to less than 20 percent.  Sources constructed, recon-
structed or modified after June 11, 1973, are subject to the regulations.

Process Description

     There are essentially two forms of ultimate municipal sewage sludge destruc-
tion of practical importance today:  incineration and wet oxidation.

     Incineration (see Figure 12)  is a two-step process involving drying and
combustion.  The drying step should not be confused with preliminary dewaterlng
by mechanical means.  Drying and combustion may be done In separate units or
successively in the same unit.  Where a two step process is employed, startup
should be applied only to the combustion step.  Many drying operations are
brought on line well in advance of the combustion unit for both checkout and
to prepare sludge for landfill while Incinerator checkout is proceeding.

     Two major incineration systems employed in the United States are the
multiple hearth furnace and the fluidized bed incinerator.  The key difference
between these systems, from a startup standpoint, is that multiple hearth
furnaces employ refractory material whereas fluidized bed units are basically
of all-metal construction.  Both incinerator types typically employ scrubbers
for air pollution control.

     The wet air oxidation process (depicted in Figure 13) is based on the
principle that any substance capable of burning can be oxidized in the presence
of liquid water at temperatures between 121°C (250°F) and 371°C (700°F).  Air
pollution is minimized because the oxidation takes place in water at low tem-
peratures and no fly ash, dust, sulfur dioxide, or nitrogen oxides are formed.
Some partlculate and odor pollution can result and catalytic burning is typically
used to control these pollutants.
                                      57

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           SLUOCC
                     DEBATER INt
                                 SLUOftE r; MCTREATMENT I «.tlO«E »
                                         I  (OPTIONAL)  '
Ln
00
INCIHEHATHMI
                             COMBUSTION
                                Aid
                                            BLOWER
             EXHAUST
              6AS
AIR POLLUTION
   CONTROL
   TO
'ATMOSPHERE
                                                                          OUT
                                                                         SOLIDS
                                                                        (ASH)
                                                                                         TO
                                                                                      DISPOSAL
                                   Figure 12.   Sewage sludge incinerator  process diagram.

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L/l




1
SLUDGE |
1



COMBUSTION
AIR *





PRETREATMCNT
(OPTIONAL)



AIR
COMPRESSOR





1
I
m
1
j






EXMAU
1,


WET AIR
OXIDATION

< > ft
I
1


ST 6AS . *>* POLLUTI



STERILE
SOLIDS SOLIDS
AMD WATER S6PARATIC



1 STEAM
— — — J GENERATOR
i tOPTIONAL)
• __
DM




IN

WE




EINAUST CAS_ TO



WATER _ WATER
* BOOT

' SOLIDS 	 TO
DISPOSAL
WATER


                           Figure 13.  Sewage sludge wet air oxidation process diagram.

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Pre-Startup Operations

     1.   Mu11ip1e Hear th:   One to two weeks are typically allowed for
          instrumentation and mechanical equipment shakedown.  This in-
          cludes the operation of the combustion air source and the
          sludge feed system.  Upon completion of this pre-startup pro-
          cedure, the unit  is heated to an operating temperature of about
          927°C (1700°F).   This must be done gradually in order to pre-
          vent stressing  of the refractory material.  Once at the operating
          temperature, the  unit remains fired until it is thoroughly
          "dryed out." The heat-up and dry-out procedure consumes
          approximately one week.

     2-   Fluidized Bed;  One to two weeks is required to perform an
          instrumentation and mechanical equipment shakedown similar to
          that for a multiple hearth furnace.  Following this,  the unit
          is heated up to its operating temperature of about 871°C
          (1600°F).   This can be done relatively quickly since  there is
          no refractory construction material.   A typical heat-up period
          is three days.  A drying-out procedure is not necessary.

     3.   Wet Air Oxidation;   One to two weeks  is required for  instru-
          mentation and mechanical equipment shakedown.  The unit is
          operated  by feeding water only as part of the procedure.  Since
          the unit  operates at only 93°C (200°F) to 204°C (400°F), the
          heat-up period is only a matter of hours.   Dry-out is not
          required.

Startup Operations

     1.   Multiple  Hearth:   After the pre-startup operations of heat-up
          and dry-out are completed,  the unit is ready to receive sludge.
          The sludge mixture,  which is mainly water,  must be charged
          slowly at  first to  prevent  thermal shocks  and gradients within
          the refractory material.   The unit must be run at  partial
          capacity  for approximately  one week while  the load is gradually
          increased.   The day  on which sludge is first  introduced to the
          unit  should officially be considered  the startup date.   Up
          until  this  point,  including post  heat-up,  the unit could be
          shut down  f c r mechanical  or instrumentation failure,  or more
          often,  for  a lack of  sludge of proper  consistency  and quantity.
          For a  multiple hearth furnace,  the maximum production rate can
          be attained one week from startup.

     2«    Fluidized  Bed;  After  the pre-startup  operation of  heat-up is
          complete,  the unit  is  ready to receive sludge.  The sludge is
          usually introduced at  a rate within 20 percent  of  design capacity
          or greater.   The  day  on which sludge  is first  introduced to  the
                                      60

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     unit should officially be considered the startup date.   Since
     sludge Is Introduced at or near the design rate, there  Is no
     time elapsed between startup and the point when the maximum
     production rate Is reached.

3.   Wet Air OxIdatIon;  After the pre-startup operation of  heat-
     up Is complete,  the unit Is capable of receiving sludge at or
     near the maximum production rate.   The day on which sludge Is
     first Introduced to the unit should officially be considered
     the startup date.  Since sludge Is  Introduced at or near the
     design rate,  there Is no time elapsed between startup and the
     point when the maximum production rate is reached.
                                61

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                                  REFERENCES
1.  Process Design Manual for Sludge Treatment and Disposal, U.S. EPA Tech-
    nology Transfer, October 1974.  IPA-625/1-74-006.

2.  Inspection Manual for the Enforcement of New Source Performance Standards
    Sewage Sludge Incinerators, by Devitt and Kulujian, U.S. EPA, Research
    Triangle Park, N.C., February 1975.

3.  Private Communication:  Richard Shedlow of Nichols Engineering and
    Research Corporation, Belle Mead, New Jersey.  March 5, 1979.

4.  Private Communication:  Ed Sweeney of Dorr-Oliver Company, Stamford,
    Connecticut.   March 6, 1979.

S.  Private Communication:  Mike Mayer of Zimpro, Rothschild, Wisconsin.
    March 12, 1979.
                                     62

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                      PRIMARY COPPER SMELTERS - SUBPART P
                               §60,160 - 60.168
Introduction

     The standards of performance for primary copper smelting affect the dry-
ing, roasting, smelting and copper converting facilities.  Gases which contain
particulate matter in excess of 50 mg/dscm (0.022 gr/dscf) from any dryer and
sulfur dioxide in excess of 0.065 percent by volume from any roasters, smelt-
ing furnaces or copper converters cannot be discharged into the atmosphere.
The standard for visible emissions limits opacity to 20 percent for dryers and
facilities using a sulfuric acid plant to comply with the standards.  Addition-
ally, sources shall install and operate a continuous monitoring system for
opacity and sulfur dioxide.  Sources constructed, reconstructed or modified
after October 16, 1974, are subject to these requirements,

Process Description

     The copper bearing ores are either smelted as they come from the mine or
are subject to a preparatory process of grinding and floatation to transform
low-percentage ores into high-percentage ores.   Ore coming directly from the
mine normally passes through a dryer to remove the moisture while grlnding-
flotatlon processed ore is subsequently smelted down either directly or after
partial roasting.  Roasting removes part of the sulfur from the ore.  There
are two main types of roasters used in the industry:  multiple hearth and
fluidized bed.  In the smelting furnace, iron oxide combines with siliceous
flux to form a slag and leaving a material known as matte composed of copper,
Iron and sulfur.  Two commonly used smelting furnaces are reverberatory and
electric smelting.  The matte in the smelting furnace is reduced to copper in
two stages of blowing with air in a unit called a converter.  The first stage
eliminates sulfur and forms an iron oxide slag by adding a siliceous flux.
The slag is then removed from the melt.   In the second stage, the copper sul-
flde is reduced to metal;  sulfur Is eliminated as SO2 leaving a material known
an blister copper.  The blister copper may be further refined to remove sulfur
and oxygen,to be cast into anodes for electrolytic refining.  Figure 14 illus-
trates a combined flow sheet of a variety of choices in current and developing
technology offered to smelter designers.  The unit/processes chosen for startup
evalatulon appear to be typical for the copper smelting industry in the United
States.                                              •
                                        63

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                             1.
      DRYER
                  3.
                       2.
     ROASTER
                            * Multiple hearth
                            * Fluid Bed
SMELTING FURNACES
                       • Blast furnace
                       * Momada Blast furnace
                       * Reverberatory furnace
                       • Flash smelting
                       • Electric smelting
                       * Cyclone smelting
                                       matte
                                CONVERTER
                           • Pierce Smith
                           * Hoboken
                           * Top blown rotary
                           • Stationary
                             .
                            slag
                          to waste
                       5.
                       S02
           Blister Copper
REFINING FURNACE
                                   T
                                 Anodes
Figure 14.   Flow  diagram for copper smelting and various unit processes,

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Fre-Startup Operations

     Dryer:  A rotary direct heat or indirect heat dryer is typically used in
the industry.  Four to seven days are allowed for dryer shakedown.  During the
shakedown period, a manufacturer's field engineer is on hand checking electri-
cal, mechanical, hydraulic and combustion systems.  Upon completion of pre-
Btartup checks, the unit will be turned over to the operator for startup or a
manufacturer's application engineer is available for complex startups.  Nor-
mally, startup is straight forward and an application engineer is not needed.
Pre-startup operation should take no longer than 1 week.

     Roaster;

     Multiple Hearth:  Two to three weeks are allowed for pre-startup operations,
If problems develop, an additional week is allowed.   Curing and heatup of the
furnace takes about 5-7 days.  This operation must be done very slowly to pre-
vent stress on refractory material.  Total pre-startup consumes a 3-4 week
period.

     Fluidized Bed:  Seven to nine days are required to perform the pre-startup
operations.  Following a successful pre-startup, the system is brought up to
operating temperature (3-4 days); the system is now ready for process material.
Total pre-startup operation may consume a 2-3 week period.

Smelting Furnace

     Electric Smelting;  Two to three weeks are required for pre-startup opera-
tions.   According to manufacturers, this period of time is known as green tag.
It also allows time for replacements of minor defective parts.   As each sub-
unit is installed, they are checked mechanically,  electrically and hydrauli-
cally as needed.  The electrodes and rigging, a major system for the furnace,
is actuated to check alignment and operation.  The electrical system is given
special attention for grounds, insulation, dead shorts, and high resistance.
Secondary voltage is then applied to the transformer conductors at a very low
current.  Transformers are then energized with primary voltage (Power company
electricity).  Curing the furnace is usually accomplished by heating with
electric energy or a supplementary fuel.  At this time, the furnace is ready
for charging.

     Copper Converters;  When a converter system is  being installed, it requires
the cooperation of many suppliers and contractors.   Upon completion of sub-unit
installation and checking, the unit is normally turned over to the owner.   The
period of time consumed during installation and checking is 3-6 months.  During
this time, all electrical, mechanical and hydraulic  systems are debugged.   Other
unite and systems checked are:  compressors, fuel  lines, levelings, fans,  pumps,
gauges, refractory linings and the cooling, chemical feed and emergency systems.
Two to three weeks are allowed to cure the refractory material of the converter.
The final step in pre-startup operation is a dry run of the entire system to
check out and coordinate the operation of individual units into a coherent sys-
tem.   A dry run normally takes 1 week.   Heating the  converter to operating
temperature requires 3 to 4 days.   The total preliminary startup operation
takes from 5 to 8 weeks.

                                      6S

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 Startup JJjura

      I)ryj2r:  Startup of  a dryer  begins  when  ore is first fed into the dryer.
 If  no problems  develop,  the  dryer  should  achieve maximum production in 1% hours.
 Special procedures sometimes require  the  presence of a manufacturer's application
 engineer  to make adjustments such  as  drum rotational speed,  material fall slope,
 and  temperature to attain the designed  moisture content in the ore.  No more
 than 2 days are required to  make final  adjustments.   Manufacturers indicated
 that the  180-day period  performance test  period should begin when material is
 first fed  to the dryer.

      Multiple Hearth;  After the pre-startup  operations, the unit is slowly
 charged with ore to prevent  thermal shocks and  gradients within the refractory
 material.  The  load is gradually increased to maximum capacity consuming 1-2
 weeks.  The official startup should be  when material is first introduced into
 the  furnace.  Prior to charging, the  furnace  could be shut down very easily
 for  repair without major time expended.

      FluidizedBed;  Following pre-startup operation and heatup,  ore is slowly
 introduced into the furnace  taking 2-4  days to  reach maximum production.   The
 official startup date should  be  when  material is  first introduced into the
 furnace.

 Smelting Furnaces

      Reverberatory Furnace;   Following  pre-startup and heat-up,  ore is slowly
 introduced into the furnace  developing  matte.   Matte is composed of copper,
 iron and some sulfur.  Flux  is then added  to  the  matte to develop an iron
 oxide slag.  In order to have a  continuous process and to develop maximum
 production, a good matte is  necessary.  The development of a good matte,  essen-
 tial  for maximum production,  may take as long as  3 to 4 weeks and is dependent
 upon  operator skills.  Inexperienced  operators  may take as long  as 2 months to
 develop a good  matte.  The official startup date  should be when  material is
 first introduced into the furnace.

      El_ec_tr ic Furnace;  After pre-startup operation  and  heat-up,  the charge is
 slowly introduced into the furnace to develop a good  matte and to prevent
 thermal gradients and shocks  to  the refractory material.   During  this period,
 flux  is also added to develop a slag.   Maximum production  cannot  be  reached
 unless a good matte exists and this again may take 3-4 weeks  depending on
 operator skills.  The official startup date should be when ore is  first  intro-
 duced into the   furnace.

      Converter;   After pre-startup operations and heat-up, the matte  from  the
smelting furnace is introduced into the converter.   If  the first heat  goes
 smoothly,  the process may continue while slowly increasing the quantity of
matte introduced into the converter until, maximum production  is reached.   It
may take as long as 6 to 8 months to develop a maximum production  rate.  The
official  startup date should begin when material is  first  introduced  into  the
converter.

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                                  REFERENCES
1.   Personal communication with Mr. Hess, U.S. Smelting Furnace Co.,
     Belleville,  Illinois,   March 1979.

2,   Personal communication with Colorado Smelting and Mine, Denver, Colorado.
     March 15, 1979.

3.   Personal communication with Treadwell Corp., New York, New York.
     March 13, 1979.

4,   Personal communication with Pyro Industries, Mlneola, New York.
     March.13, 1979.

5.   Personal communication with General Precision Systems, Glendale,
     California.   March 1979.

6.   Personal communication with Mr. Fluggie, Hevi Duty Heating Equipment,
     Watertown, Wisconson.   March 9, 1979.

7.   Personal communication with Mr. Galbreath, Whiting Corporation, Harvey,
     Illinois. March 9,  1979.

8.   Personal communication with Mr. Bruecker, Surface Combustion,  Toledo,
     Ohio.   March 13, 1979.

9.   Personal communication with the Copper Development Association, New York,
     New York. March 14,  1979.

10.   Personal communication with Mr. Farkes and Mr.  Nelson, Dwight Lloyd
     Research Laboratories,  McDowell-Wellman Engineering Co.,  Cleveland, Ohio.
     March 14, 1979.

11.   Personal communication with Mr. Naglte, Pennsylvania Engineering,
     Pittsburgh,  Pennsylvania/  March 14, 1979.

12.   Personal communication with Mr. Douglas, Lectromelt Corporation,
     Pittsburgh,  Pennsylvania.   March 9, 1979.

13.   Personal communication with Mr. Kuzlo, GE Raymond Bartlett Snow, New
     York,  New York.   March 16,  1979.

14.   Personal communication with Mr. Persons, Lectromelt Corporation,
     Pittsburgh,  Pennsylvania,   May 8,  1979.


                                     67

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15.  Personal communication with Mr. Priestly, Door Oliver, Stamford,
     Connecticut.  March 1979.

16.  Personal communication with Mr. Defull, Colorado School of Mines
     Research Institute, Denver, Colorado.  March 1979.
                                     68

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                      PRIMARY ZINC SMELTERS - SUBPART Q
                              §60.170 - 60.176
Iiitroductlcjn

     Affected operations within this category are roasting (multiple hearth
and fluid bed) and sintering.  Participates discharged into the atmosphere
from a sintering machine are not to exceed 50 mg/dscm (0.022 gr/dscf) while sul-
fur dioxide discharged from any roaster is noc co exceed 0.065 percent by
volume.  A sintering machine which drives off more than 10 percent of the sul-
fur initially contained In the zinc sulflde ore concentrates is considered a
roaster.  Visible emissions are limited to 20 percent opacity from any sintering
machine or from any affected facility that uses a sulfuric acid plant to
comply with the standard.  The owners or operators of a zinc smelter are re-
quired to install and operate a continuous monitoring system for opacity and
sulfur dioxide.  Sources constructed, reconstructed or modified after
October 16, 1974, are subject to the regulations.

Process Description

     Zinc is typically found in ore called sphalerite containing impurities
of lead, cadimum and trace elements.   Sphalerite Is normally processed at the
mines to form concentrates containing up to 62 percent zinc and 32 percent
sulfur.  The smelting of zinc sulfide into oxide or metallic zinc Is carried
out by either a pyrometallurgical or a combined pyrometallurgical-electrolytic
extraction process.  The three primary steps of the pyrometallurgical extrac-
tion process are:

     1.   roasting (multiple hearth and fluid bed) of zinc sulflde
          concentrates to remove impurities and to form an Impure
          zinc oxide called calcine.

     2.   sintering of the calcine to eliminate remaining sulfur,
          volatilization of lead and  cadmium and formation of a
          dense permeable furnace feed, and

     3.   pyrometallurgical reduction of the zinc oxide to metallic
          zinc.

The smelting of zinc sulfide using electrolytic extraction requires two
principal operations;

     1.   roasting, and

     2.   electrolytic extraction,  after chemical leaching of calcine
          to produce 99.9 percent pure high grade zinc.


                                     69

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 Figure  15 illustrates the pyrometallurgical and  associated  process  units
 typically used in each  step.  NSPS limit  emissions  from roasting and sintering
 operations and therefore, a startup evaluation was  not  conducted for the
 pyrometallurgical-electrolytic extraction process.

 Pre-Startup Operat ions

     RoaHting-Mu11iple  Hearth:  Two to  three weeks  are  allowed  for  pre-startup
 operations.   If problems develop, an  additional  week is allowed.  Curing  the
 furnace and heat-up takes about 5-7 days.  The off-gas  stream temperature is
 about 700°C (1,292°F).  The heat-up must  be done very slowly  to prevent stress
 on refractory material.  The total pre-startup operation may  consume a 3-4
 week period.

     Roast ing-FluidJed!  Seven to nine days are required for pre-startup
 operations.  Three to four days are needed for the heat-up period.   A fluid  bed
 furnace does not have refractory material  so the furnace does not need
 curing.  The total time allowed for pre-startup  is 2-3 weeks.

     Sintering Machine:  The installation and checkout of a sintering machine
 ±a a very complex operation Involving many suppliers and contractors.  This
 period of time is called construction and  teat-out and may require  3-4 months
 to complete.   A major factor affecting the length of this period of  time  is
 the geographical location of the plantj isolated areas may make it difficult
 to obtain spare parts thus, delaying startup.  The pre-startup operation is
 the most hazardous period during which component parts may be damaged.  The
 test-out is done without load material.  Some of the items checked are:
 instrumentation,  structure, electric motors, mechanical  clearances, conveyor
 belts,  mixing drums, sinter breakers,  and coolers.   Curing the machine
 ia a 5  to 7 day operation.   Upon successful completion of the construction and
 test-but,  the sintering machine is ready to receive material.  The maximum
 time period for construction and test-out is 6 months.

 Startup Operations

     RoastinR-Multiple Hearth;   After  pre-startup operations, ore is slowly
Introduced  into the  furnace in order to prevent  thermal shocks and gradients
in refractory  material.   The  load  is gradually increased to  maximum capacity
over a  1 to 2  week  period.   The startup date should be  defined as the time
material (ore)  is  first  introduced into the furnace.

     Roasting-FluidBed;  Following the pre-startup and heat-up operations,
 the ore is  slowly  introduced into  the  bed, increasing to the maximum feed rate
 in 2-4  days.   The  official  startup date should begin when material is first
introduced  into the  bed.
                                      70

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 Oxide
furnace
    _

  ZnO
                                 concentrate
                                  ROASTING
                         * ROPP & Multiple Hearth
                         • Flash
                         • Fluid Bed
                                          Calcine ZnO
                                  Metallic
                                    zinc
S02
      Figure 15.   The  pyrometallurglcal  process.
                          71

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     Sintering Machine;   After the pre-startup operation and heat-up is com-
pleted, the sintering machine normally goes into a one shift per day operation
for 2-3 weeks.  This period allows the operators to become familiar with the
equipment.  Each daily startup takes about 1% hours to produce a product.
Before going into maximum production, the machine will go into a 24 hr/day
operation for about 2 weeks.  By the end of the second week, operators and the
machine should be ready for maximum production.  However, the inexperienced
operator will extend this time.   On the average, the sintering machine and
operator should be able to reach maximum production in 3-6 months.  The time
needed to reach maximum production for a sintering machine varies; new sinter
machine designs and new processes require more attention than off-the-shelf
sintering machines.  The first year's production rate normally ranges between
70 to 80 percent because of malfunctions and repair time; however, the produc-
tion rate usually Increases in the succeeding year to a maximum production
rate (90 to 100 percent).  The official startup date should be designated as
the day when material is first introduced into the machine.  Manufacturers
indicated that 180 days  is a reasonable time period in which to reach maximum
production for conducting performance testing.
                                      72

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                                  REFERENCES
1.   Personal communication with Mr. Williams, Dwight Lloyd Research Labora-
     tories, McDowell-Wellman Engineering Co., Cleveland, Ohio,  March 1979,

2.   Personal communication with Pyro Industries, Mineola, New York.
     March 1979.

3,   Personal communication with Mr, Bruecker, Surface Combustion, Toledo,
     Ohio.  March 1979.

4,   Personal communication with Mr. Nelson, Dwight Lloyd Research Laboratories,
     McDowell-Wellman Engineering Co., Cleveland, Ohio.   March 1979.

5.   Personal communication with Mr. Coulter, Dravo Corporation, Pittsburgh,
     Pennsylvania,   March 15, 1979.

6.   Personal communication with Mr. Farkes, Dwight Lloyd Research Laboratories,
     McDowell-Wellinan Engineering Co., Cleveland, Ohio.   March 14, 1979.

7.   Personal communication with Mr. Latoweski, Kopper Company, Pittsburgh,
     Pennsylvania.   March 15, 1979.

8,   Personal communication with Mr. Nell,  the Bethlehem Corporation, New York,
     New York.  March 14, 1979.

9,   Personal communication with Mr. Smith,  Mine and Smelter Supply, Denver,
     Colorado.  March 1979.

10.  Personal communication with Mr. Priestly, Door Oliver, Stamford,
     Connecticut.   March 1979.
                                     73

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                      PRIMARY LEAD SMELTERS - SUBPART R
                              160.180 - 60.186
Introduction

     This NSPS category regulates the following facility operations for primary
lead smelting:  sintering machines, sintering machine discharge end, blast
furnaces, drosa reverberatory furnaces, electric smelting furnaces and con-
verters.  Particulate emissions from any blast furnace, dross reverberatory
furnace or sintering machine discharge end are limited to 50 mg/dscm (0.022
gr/dacf).  Sulfur dioxide is limited to 0.065 percent by volume from any
sintering machine, electric smelting furnace, or converter.  Opacity is limited
to 20 percent from blast furnaces, dross reverberatory furnaces, sintering dis-
charge end, or any facility that uses a sulfuric acid plant to comply with
standards.  Lead smelting facility owners and operators are required to install
and operate continuous monitoring equipment for opacity and sulfur dlojcide.
Sources constructed, reconstructed or modified after October 16, 1974, are
Subject to the regulations.

Process Description

     Lead is found in nature as a sulfide ore containing impurities of copper,
zinc and other trace elements.   At the mines, the lead ore is normally concen-
trated to 65-70 percent.   Typically, the concentrate contains between 13-19
percent by weight of sulfur.  The production of lead includes the following
operations;

     Sintering;  Lead and sulfur are oxidized to produce lead oxide and to
reduce the sulfur dioxide concentration to 85 percent.   Simultaneously, the
charge material composed  of recycled sinter, Band and Inert material is
agglomerated to form a dense,  permeable  material called sinter.   The sinter
Is then charged to a reduction unit such as a blast furnace.

     Reduction!  In the blast  furnace, lead oxide is reduced to a molten lead
bullion.  The lead bullion then goes to the refinement steps,

     Refinement;  Impurities are removed from the lead bullion.

Figure 16 illustrates a flow diagram of a lead smelting process.   Smelting
manufacturers Indicated that electric furnaces and converters are not used in
the U.S. because of the high cost of energy; therefore, a startup evaluation
•as not conducted for these units.
                                      74

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                   2.
                        1.     SINTERING
                S0?
 REDUCTION
                         Blast  furnace
                         Dross  Reverberatory
                         Electric Smelting
                       3.
                                      lead bullion
REFINEMENT
                             Converter
                                      lead
Figure 16.   Lead  smelting  flow diagram with  typical process units,
                                75

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Pre-Startup Operat ions

     SinteringMachine:  The installation and checkout of a sintering machine
±B a very complex operation involving many suppliers and contractors.  This
period of tine Is called construction and test-out; it may last 3-4 months.  A
major factor affecting the length of this period is the geographical location
of the plant; isolated areas may make it difficult to obtain spare parts thus
delaying startup.  The pre-startup operation is the most hazardous period dur-
ing which component parts may be damaged.  The test-out is done without load
material.  Some of the items checked are:  instrumentation, structure,
electric motors, mechanical clearances, conveyor belts, mixing drums,
sinter breakers, and coolers.  Curing the machine is a 5-7 day operation.  In-
experienced operators are a major problem in achieving a maximum production
rate within a reasonable time frame.  Upon successful completion of the con-
struction and test-out, the sintering machine is ready to receive material.
The maximum time period for construction and test-out is 6 months.

     Reduction - Blast Furnace;  The blast furnace for lead smelting is unlike
that used in the Iron and Steel industry In that it has no refractory material,
thereby eliminating the curing requirement.  When a lead blast furnace is
Installed or reconditioned, each system is checked and reconditioned or re-
placed.  A final checkout is then conducted coordinating the functions of all
systems and units operating at rated capacity.  This test period takes 2-3
hours.  Some of the major systems/units examined are the water packet cooling
system, flange corking, charging, weighing, fuel and all mechanical, electri-
cal, and hydraulic systems In general.  The furnace is now ready to receive
a charge.

     Reduction- Dross Reverfaeratory;   Once the furnace is installed and all
connections made, pre-startup operations begin.  The pre-startup operaton
takes 2-3 days.  Simultaneously, the furnace is cured for 4-7 days depending
on the size of the furnace.  Finally,  the furnace is- brought up to operating
temperature and stabilized (2-3 days).  The furnace is now ready to receive
material.  The total pre-startup operation consumes 5-7 days.

     Reduction - Electric Furnace:  Electric furnaces In the lead smelting
Industry are used for melting rather than smelting.  The energy is too demand-
ing for a smelting operation.  Two to  four weeks are allowed for pre-startup
operations.  Manufacturers call this period of time the green tag period
(test-out).  Individual, mechanical, electrical and hydraulic components are
checked.  Special attention Is given to electrode rigging, electrical grounds,
shorts and high resistance.  Upon successful completion of all checks, a low
secondary voltage is applied to the transformer.   If no problems develop, the
primary voltage (Electric Company) energizes the entire system.  Curing the
furnace is either done with electrical or fossil fuel energy.  Curing consumes
a 3-4 day period and is normally done  during the green tag period.  The total
pre-startup operations take about 1-2  weeks.
                                     76

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 Star tup Ope r a t ions

      Sintering Machine:   After the pre-startup operation and heat-up is com-
 pleted, the sintering machine normally goes into a one shift per day operation
 for 2 to 3 weeks.   This  period allows the operators to become familiar with the
 machine.  Each daily startup takes about 1^ hours to produce a product.  Before
 going into maximum production, the machine will go into a 24 hr/day operation
 fdr about 2 weeks.   By the  end of the second week, operators and the machine
 should be ready for maximum production.   On the average,  the sintering machine
 should be able to  reach  maximum production in 3 to 6 months.  The time needed
 to reach maximum production for a sintering machine varies,  new sinter machine
 designs and new processes require more attention than off-the-shelf sintering
 machines.   The first years  production rate normally ranges between 70 to 80
 percent because of  malfunction and repair time; however,  the production rate
 usually increases  in the succeeding year to maximum production rate (90 to 100
 percent).   The offical startup date should be when material  is first introduced
 into the machine.   Manufacturers  indicated that the 180 day  performance test
 period is  a reasonable time in which to  reach maximum production.

      Reduction - Blast Furnaces:   Following a 2-3  hour pre-startup,  the furnace
 is  ready to receive  a  charge and  will  normally reach a maximum production  rate
 in  24 to 48  hours.   The  startup procedure  for a lead blast furnace  first re-
 quires  the  hand stacking of wood  in  the  furnace.   This operation  takes  6-12
 hours depending on  the size of  the  furnace.   Next,  the blast  furnace is charged
 with  oil-soaked coke  (3-5 hours).  The blast  furnace is ignited, brought up  to
 operating  temperatures and  sinter  is slowly fed into the  furnace until  the
 maximum charge rate  is reached.  During  this  time,  other  materials  such as
 limestone,  silica,  litharge and slag-forming  materials are added  to  the furnace
 to  develop  a high quality lead bullion pool for continuous operation.   If  the
 charge  period  goes smoothly, a blast furnace  can reach maximum production  in
 24  hours; however, minor problems  will extend this  time to 2  days.   The life of
 a blast  furnace normally does not  exceed 180  days,  therefore, there  should be
 no  problems  in testing this unit under maximum production conditions with  the
 specified time (180 days).   The official startup should be designated as the
 time when the wood and coke are first ignited.

      Reduction - Dross Reverberatory:  After pre-startup  and heat-up operations,
 lead  bullion is slowly fed into the furnace to  prevent thermal shpck and to
 maintain a stable temperature.  The time required to reach maximum production  is
 3-5 days after material is first introduced into the furnace.  The total time
 required from a cold start to maximum production will  range from 5-7 days.  The
 official startup date should be when material  is first introduced into  the
 furnace.

     Reduction - Electrical Furnace;  Following pre-startup and heat-up, lead
 bullion  is slowly introduced into the furnace.  The  transformer is then ener-
 gized, heating the furnace  and charge to desired temperatures; the introduction
 of more charge lowers the temperature and the  furnace  is energized again.  This
 operation occurs many times  until the furnace is filled to maximum capacity.
The time required to reach  maximum production is about 5 days from a cold start.
Two to three days are considered heat-up time.  The official  startup date should
begin when material is first introduced into the furnace.


                                       77

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                                  REFERENCES
 1.   Personal communication with Mr. Williams,  Dwight  Lloyd  Research Labora-
     tories, McDowell-Wellman Engineering  Co.,  Cleveland,  Ohio.   March 1979.

 2.   Personal communication with Mr. Schick, Mohr  John and Son,  Chicago,
     Illinois.  March 1979.

 3.   Personal communication with Mr. Gallaway,  Chicago Bridge  and Iron,
     Chicago, Illinois.  March 1979.

 4.   Personal communication with Mr. Gail,  Ingall  Iron Works,  Birmingham,
     Alabama.  March 1979.

 5.   Personal communication with Colorado  Smelting and Mine, Denver,  Colorado.
     March 1979.

 6.   Personal communication with Mr. Johnston,  St. Joe Lead  Co.,  Herculaneun,
     Missouri.  March 29, 1979.

 7.   Personal communication with Mr. Boyd,  the  Bunker  Hill Company,  Kellogg,
     Idaho.  March 29, 1979.

 8.   Personal communication with Rico Argentine Mining Co.,  Rico,  Colorado.,
     March 29, 1979.

 9.   Personal communication with Mr. Nelson, Dwight Lloyd  Research Labora-
     tories, McDowell-Wellman Engineering Co.,  Cleveland,  Ohio.   March 1979.

 10.  Personal communication with Mr. Coulter, Dravo Corporation,  Pittsburgh,
     Pennsylvania.  March 15, 1979.

 1.1.  Personal communication with Mr. Farkes, Dwight Lloyd Research Laboratories,
     McDowell-Wellman Engineering Co.,  Cleveland, Ohio.  March 14, 1979.

12.  Personal communication with Mr. Latoweski, Kopper Company, Pittsburgh,
     Pennsylvania. March 15, 1979.

13,  Personal communication with Mr. Jensen, AMAX Lead Homestake, Buick Mines,
     Missouri.   March 1979.

14.  Personal communication with Mr. Douglas, Lectromelt Corporation, Pittsburgh,
     Pennsylvania. March 9,  1979.
                                      78

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15,   Personal communication with Dr. Lyman and Dr. Cole, Lead Industrial
     Association, New York, New York.  March 1979.

16,   Personal communication with Mr. Priestly, Door Oliver, Stamford,
     Connecticut.  March 1979.
                                     79

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                PRIMARY ALUMINUM REDUCTION PLANTS - SUBPART S
                              §60.190 - 60.195
Introduction

     (Amendments to the NSPS for this category will be promulgated shortly;
the requirements detailed here incorporate these amendments.)

     The NSPS for this category applies to potroom groups and anode bake plants,
regardless of size, which are located at primary aluminum reduction plants.
Performance tests are required at least once each month during the life of the
affected facility, but the owner or operator may petition the EPA administrator
to establish an alternative requiring less frequent testing for a primary con-
trol system or an anode bake plant.

     Performance standards have been established for fluorides and opacity.
Fluoride emissions are limited to:  (1) 1.0 kg/Mg (2.0 Ib/ton) of aluminum
produced for potroom groups at Soderberg plants; (2) 0.95 kg/Mg (1.9 Ib/ton)
of aluminum produced for potroom groups at prebake plants; and (3) 0.05 kg/Mg
(0.1 Ib/ton) of aluminum equivalent for anode bake plants.  Potroom emissions
could exceed the applicable Soderberg or prebake plant standard, but could
never exceed 1.30 kg/Mg (2.6 Ib/ton), if an owner or operator could establish
that the emission control system was properly operated and maintained at the
time the excursion above the standard occurred.  Opacity must be less than
10 percent for potroom groups and less than 20 percent for anode bake plants.
Sources constructed, modified, or reconstructed after October 23, 1974 are
subject to the regulations.

Process Description

     All aluminum produced in the United States is by electrolytic reduction of
alumina (A1203).  Alumina is itself a product produced from Bauxite ore.  Fig-
ure 17 presents a flow diagram of the aluminum reduction process.   The process
is carried out in shallow rectangular cells (Pots) constructed of carbon coated
steel shells (cathodes) utilizing consumable carbon blocks (anodes) which are
suspended above and extend down into the pot.  A series of these cells, when
connected to a common electrical supply, is considered a potline.   Potlines are
normally constructed as two adjacent buildings approximately 1,200 ft long.

     Cryolite, a double fluoride salt of sodium and aluminum (Na3AlFe), serves
as both an electrolyte and a solvent for alumina.   The resistance of the cells
causes them to be heated and operate between 950°  and 980°C (1,740° to 1,830°F).
During the reduction process, aluminum ions are reduced to aluminum.   The
oxygen released reacts with the anode to form carbon dioxide and carbon mon-
oxide.   Molten aluminum is periodically tapped from beneath the cryolite bath
and moved to holding furnaces prior to being cast  into ingots.

                                     SO

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OO
                                           CALCINED
                                           PETROLEUM
                                             COKE
                                                                                             CALCINED
                                                                                            PETROLEUM
                                                                                               COKE
                                                                                           ANODE  PASTE
                                   ELECTRICITY
                                                                         T
                                                                          •—
                                                                            ELECTRICITY
                                         CHLORINE 	
                                        AND CHLORIDE
                                           SALTS
REFINING
AND
CASTING
                                                         CAST ALUMINUM
                                                             TO
                                                           SHIPPING
                         Figure 17.   Process flow diagram  for primary  aluminum  reduction.5

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     Three different types of cells are used for the  production  of  aluminum;
the vertical stud Soderberg (VSS), the horizontal stud  Soderberg (HSS), and the
prebake (PB).  These cells differ in the design for introducing  the electrical
current to the cryolite bath.  Soderberg cells utilize  a consumable anode which
is baked insitu.  A mixture of ground petroleum coke and coal tar  pitch is
periodically added to the top of the anode to renew it.  Heat from  the process
bakes the lower boiling organics and fuses the new material to the  old anode.
This system precludes the need for a separate anode baking facility.

     The PB cell uses an anode that is prebaked.  Since the anode is consumed
during normal operation, the old anode remnants (butts) are replaced periodically
with new anodes.  These butts are cleaned, ground, mixed with new coke and
blended together with coal tar pitch in an anode plant.  The mixture is weighed,
formed into bricks, then slowly baked in a furnace.  This process cycle can
take up to 60 days.

     Fluoride emissions from these processes are controlled by several methods:
dry scrubbers (baghouses), venturl scrubbers, wet electrostatic precipitation,
or impingement devices.  Dry scrubbers are the most common, and all utilize
cell grade alumina to adsorb the gaseous fluoride.  This alumina is then used in
the pots for electrolytic reduction.  Various methods such as coated bags,
alumina injection, and fluidized bed dry scrubbing, are employed to provide
fluoride/alumina contact.

Prg-Startup Operations

     In a prebaked operation, the anode plant is necessarily constructed and put
into operation 2 to 6 months before aluminum is produced in the potline opera-
tion.  This insures that a sufficient supply of anodes is available for produc-
tion.  Anode production Involves crushing, shaking, screening, classifying,
mixing, pressing, and baking of the raw materials.   Each of these mechanical
systems is checked without load prior to startup.   These tests are made after
each system is operational and collectively will take 2 to 3 months.  When the
anode plant includes a baking furnace,  it must be conditioned by curing the
refractory for 2 to 3 weeks on a low fire before the first green anodes are
baked.

     Major components of an aluminum reduction plant include materials handling
equipment (cranes, conveyors, pumps),  electrical equipment (rectifiers, trans-
formers,  busbars), steel-shell pots and associated  anode support structure, and
the air pollution control equipment.   These systems are all individually checked
before plant startup to insure they are operational.  However, all systems,
especially the electrical and control equipment, require a load to insure they
meet design specifications.

     The  green cathode is "baked-out" by placing resistor coke in the pot and
setting the anode on this coke.   Current applied through the anode serves to
heat, dry, and bake the green cathode lining.  This operation takes two days
per pot,  and is the initial step of startup.
                                      82

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Startup Operations

     Prebake plants (considered likely to be the most widely used type in the
future) require that pots be started sequentially, such that startup of a pot-
line is considered to be the day the first pot produces aluminum at its designed
capability.  A preliminary step in potline startup (those equipped with
dry scrubbing/bflghouse systems) is the activation of the primary air pollution
control system, including alumina movement through the system.  This ensures
that fluoride emissions from all pots are controlled as they come on line.  De-
sign flow rates and temperatures, however, are not reached until all pots are in
service.  The individual pots are placed on line, one at a time, with a maximum
of three or more pots started per day.  Some plants may elect to introduce up
to 20 pots at one time.  In these cases, the pots are operated for 1 week before
additional pota are energized.   For typical potline sizes of 100 to 180 pots,
the entire startup procedure may last from 150 to 300 days.  In light of the
fact that this time frame may exceed the 180-day testing requirement, enforce-
ment proceedings may be required to establish performance testing schedules
at individual plants.   Greenfield (new potline in a new location) pot startup
is accomplished by adding powdered cryolite to a pot and slowly heating it to
970°C (1,780°F).  During this time, the anode-cathode distance is opened, the
electrical equipment is monitored for short-circuits and the pots are contin-
ually inspected to insure against breakdown of the cathode lining and anode
overheating.  This phase is critical as a poorly adjusted anode can quickly
overheat and destroy the cathode lining.  Since the pots are connected in
series, an electrical failure will trip the entire potline.  Initiation of
metal tapping takes from 7 to 10 days after alumina is added, as a stable mol-
ten aluminum pad must be established in every pot.  Testing would be required
within 60 days of the last pot  being put into service.

     Startup of an anode bake plant is considered to be the first baking of
green anodes.  Fluoride emissions from this operation will commence (a) with
this first bake, if the anode plant is an expansion of an existing facility
and butts, containing fluoride, are recycled, or (b) with the initial recycling
of butts in a greenfield operation.

     Soderberg plants, which are not likely to be chosen for new sources in the
years to come, may require from 180 to 360 days to meet maximum potline produc-
tion, as the physics of in-situ anode production is complex and there is greater
potential for problems.  Since  the anodes are baked in-situ, the entire anode
production process must be de-bugged before aluminum production can begin.
The initial anode for .each pot  must be mixed, incorporated into a support sys-
tem, connected electrically and then baked before alumina is added.   An attempt
at production can be made once  the individual anode is ready.  Should an anode
problem occur the entire support assembly must be disassembled, and a new anode
mixed, reassembled and baked before another attempt is made.  As this time con-
suming procedure may occur at each pot, the ability of an entire potline to
meet maximum production may be  delayed, requiring enforcement proceedings to
establish performance testing schedules.
                                     83

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                                 REFERENCES
1.    Personal communication with Mr. Alberts, Noranda Corporation, New Madrid,
     Missouri.   March 29, 1979.

2.    Personal communication with Mr. Howarth, Alumex Corporation, Buc Keystown,
     Maryland.   March 29, 1979.

3.    Personal communication with Mr. Jansen,  Eastalco Corporation, Frederick,
     Maryland.   March 30, 1979.

4.    Personal communication with Mr. Yeager,  Anaconda Aluminum Corporation,
     Louisville, Kentucky.   April 23, 1979.

5.    Technical  Guidance for Control of Industrial Process Fugitive Particulate
     Emissions.   1977.   U.S.  Environmental Protection Agency, EPA-450/3-77-010.

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              WET PROCESS - PHOSPHORIC ACID PLANTS - SUBPAJRT T
                               §60.200 - 60.204
 Introduction

     For the purposes of this regulation, wet process phosphoric acid plants
 are defined as any facilities manufacturing phosphoric acid by reacting phos-
 phate rock and acid.  Affected facilities include  any combination of reactors,
 filters, evaporators, and hotwells.  Emissions of  total  fluorides are limited
 to 10 g/metric ton (0.02 Ib/ton) of equivalent P205  feed.  Equivalent P205
 feed is defined as the quantity of phosphorous, expressed  as phosphorous
 pentoxide, fed to the process.  Sources constructed, reconstructed, or modi-
 fied after October 22, 1974., are subject to the regulation.

 Process Description

     The sulfuric acid or wet process produces phosphoric acid by the reaction
 of phosphate rock with sulfuric acid which also results in the precipitation of
 calcium sulfate (gypsum).  Figure 18 is a simplified flow diagram of the pro-
 cess.   Phosphate rock is ground in a special ball mill with dilute phosphoric
 acid (recycled) and the resultant slurry mixture is then passed into multiple
 reactor and digesting tanks for reaction with sulfuric acid.   Cooling is re-
 quired to remove the  heat of reaction.   Water vapor and gaseous impurities are
 carried to an absorber where fluosilicic acid is recovered.  Acid digestion of
 the slurry requires 4 to 8 hours at temperatures of about 75°C (167°F).   Violent
agitation and close temperature control are required for the production of
uniform, easily washed and filtered gypsum (CaSOi^ • 2H20) crystals.   Without
 this close control, the anhydrite would form,  become subsequently hydrated, and
result in plugging of pipes.

     Slurry from the  digester tanks passes into horizontal, rotating, tilting-
pan-type vacuum filters where phosphoric acid (30 to 35 percent P20s) is removed
 from the filter cake.  This acid filtrate is then concentrated to 54 percent
P205 by evaporation.

Pre-Startup Operations

     Mechanical checkout is begun as soon as specific units or groups of inter-
related units are reported as mechanically complete by the construction con-
tractor.  These checks include;

    •     alignment of all motor driven equipment

    «     hydrostatic testing of all liquid  handling equipment


                                     85

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                                          WATER
                                     6ASCS
00
01
                                                                    FLUOSILICIC
                                                                  *• ACID TO RECOVERY
        PHOSPHATE ROCK
         (CALCINED)
                                                    FLUORINE
                                                    SCRUBBED
    VACUUM FLASH COOLER
SULFURIC
  ACID
                                                                    WASH WATER
                                                                              ROTARY OR
                                                                              TILTIN6
                                                                             IRAN FILTERS
                                                            FILTRATE
                                                            RECEIVERS
                        WEAR PHOSPHORIC ACID RECYCLE
                                                                                          VACUUM
                                                                                         EVAPORATOR
                                                                     PHOSPHORIC ACID
                                                                       130-38%
                                                                                                TO GYPSUM
                                                                                                   POND
                                                                                            PHOSPHORIC ACID
                                                                                               (54%
            Figure 18.   Flow diagram of the wet-process phosphoric  acid production process.

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     Q    Initial checkout of all Instrumentation loops, with physical
          or electronic calibration where possible

     ®    Integrity check of all electrical circuits and proper rotation
          of electrically driven units

     O    proper performance of vacuum generating equipment and vacuum
          handling equipment such as flash coolers and filtration units.

     These steps would be carried out by both maintenance and mechanical
engineering personnel and would take at least 1 week.  Any significant design
faults or failures could appreciably alter this time period.

     Once mechanical acceptance has been completed, process evaluation is be-
gun by operating all units "on water" to check for leaks and to evaluate pump
capacities and instrument calibration.

Startup Operations

     Once the system has been operated on water for a long enough time to
insure equipment integrity and the ability of driven equipment to perform
within design limits, staged operation can be initated.  Startup is best
defined as the point when phosphate rock and sulfurlc acid are first added to
the reaction vessel.  The normal feed ratio is about 726 Kg (0.8 tons) of 100
percent sulfuric acid per 907 kg (ton) of rock and varies depending on the
quality of rock.  These two raw materials are added at low rates initially,
until the slurry in the reaction tank is of proper concentration and consis-
tency.  Under normal circumstances, this initial charging of the reactor can
take 8 to 16 hours while the proper concentration is usually achieved in 16
to 48 hours.   The plant is then operated at continuous flow conditions but
only at half capacity.   As confidence in and knowledge of equipment and process
is gained, rates are increased to design levels.  This can involve 1 to 3 weeks
in the absence of unusual circumstances.  Once design capacity is achieved,
the plant initiates a 5 to 7 day test period, during which time all operational,
mechanical,  and chemical parameters must be measured to insure that all equipment
operates within design conditions and chat all guaranteed process rates,
efficiencies, and recoveries are met.  Upon completion of a successful test
period, the plant is legally accepted (possibly with provisions to upgrade
equipment if necessary).
                                      87

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                                 REFERENCES
1.   Personal communication with Mr. G. M. Hebbard, New Wales  Chemicals,  Inc.,
     Mulberry, Florida, March 23 and March 27, 1979.

2.   Personal communication with Mr. Alan Martin, W. R. Grace  and  Company,
     Bartow, Florida, April 6, 1979.

3.   Personal communication with Mr. Robert Schmidt, Gardinier,  Inc.,  Tampa,
     Florida, April 18, 1979.

4.   Personal communication with Mr. James C. Daniel, U.S.S. Agrichem/Division
     U.S.S.  Steel,  Fort Meade, Florida, May 18, 1979.
                                      88

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                    SUPERPHOSPHORIC ACID PLANTS  -  SUBPART U
                               §60.210 - 60.214
 Introduction

     Superphosphoric acid plants regulated under this part are defined as any
 facility which concentrates wet-process phosphoric acid to 66 percent or greater
 phosphorous pentoxide (P20s) content by weight for eventual consumption as a
 fertilizer.  Affected facilities include any combination of evaporators, hot-
wells, acid sumps, and cooling tanks.  Total fluoride emissions are limited to
 5 g per metric ton (0.01 Ib/ton) of equivalent P20s feed, defined as the
quantity of phosphorous pentoxide fed to the process.  Sources constructed,
reconstructed or modified after October 22, 1974, are subject to the
regulation.

Pro ce ss Description

     Superphosphoric acid is produced by concentrating 54 percent ?2°5 phos-
phoric acid to about 70 percent (± 2 percent) P20s.   Two commercial processes
used to accomplish this are vacuum evaporation and submerged combustion, al-
though the latter process is virtually outdated.   In the vacuum evaporation
proceaa, depicted in Figure 19, clarified 54 percent P20s acid is continuously
fed to a vacuum evaporator from which hot gases containing water vapor and
fluorides are condensed in the water-cooled barometric condenser.  Condenser
water flows to the hotwell prior to draining to the  gypsum pond.   Concentrated
acid is drawn from the evaporator to cooling tanks and then to storage.

     In the submerged combustion process, Figure  20, hot gases are forced
below the surface of the 54 percent ¥2^5 phosphoric  acid in a submerged com-
bustion evaporator.   Mater vapor, fluorides, and  acid mist are driven from
solution and concentrated acid is drawn off as product.

Pre-Startup Operations

     The major piece of equipment requiring a thorough mechanical checkout is
the evaporator.   In the past,  falling-film evaporators have been  used but have
been replaced more recently with forced-circulation  units.   A disadvantage of
the falling-film type was the  inability to uniformly distribute the liquid
as a film inside the exchanger tubes.

     The evaporator  is  typically a shell and tube exchanger with  high pressure
steam input,  a high-volume,  low-head,  recirculation  pump,  and is  operated at
about 6.75 to 20.3 kPa (2 to 6  in.  Hg)  absolute pressure.   Initial checking of
the evaporator assembly is carried out  by the contractor while the plant will
                                      89

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54% P

  ACID
                  VACUUM
                EVAPORATOR
                             STEAM
                  PRODUCT
                  COOLER
                                                 1
                                             BAROMETRIC
                                              CONDENSER
                                              / k
SCRUBBER
                                               HOTWELL
                                -»TO  STORAGE
                     TO
                 ATMOSPHERE
SEPARATOR
                   GYPSUM
                     POND
       Figure 19.  Superphosphoric  acid  production by the vacuum evaporation process.

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                                                                              TO
                                                                         ATMOSPHERE
                                                   >TO STORAGE
Figure 20.   Superphosphoric acid production by the submerged combustion process.

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perform their own debugging procedures when the equipment is delivered.  The
plant would check the circulation pump for alignment, rotation, and with
couplings disengaged, and also check bearings and packing.  All acid—handling
equipment is filled with fresh water for about 2 hours during which time leaks
are detected and pumps, ammeters, flow meters, etc. are checked for capacity
and calibration.  A plant engineer will also inspect the equipment for proper
welds and to verify the construction material (usually Hastelloy G - 20 to 30
percent nickel).  Operating vacuum is then pulled on the system and held for
at least 8 hours to check for vacuum leaks.  Steam lines are then blown out
to remove mill scale, welding rods, or other extraneous materials.  Water and
steam are then introduced to the plant and the water is evaporated for 5 to 6
hours to check pumps, instrument loops, control valves, and other pertinent
components.

Startup Operations

     Upon completion of the process equipment checks,  the system is recharged
with acid and the acid  feed is initiated;  this can be  considered as plant
startup.   For normal circumstances involving no equipment failures or innovative
designs requiring additional process evaluations,  the  preliminary equipment
checks consume about 2  weeks and the maximum design rate can be achieved in
about 48 hours.   Approximately 2 to 3 weeks after the  startup period,  a per-
formance run of about 3 days will begin,  during which  time all phases of opera-
tion must be as specified  including emission rates and plant efficiency ex-
pressed as unit weight  of  product per unit weight  of steam Input.   Under normal
conditions,  180 days Is adequate time for conductance  of source tests.
                                     92

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                                 REFERENCES
1.   Personal communication with Mr. Jack Smith, J. R. Simplot  Co.,  Pocatello,
     Idaho, May 15, 1979.

2.   Personal communication with Mr. C. G.'Meier, Farmland Industries, Bartow,
     Florida, May 15, 1979.

3.   Personal communication with Mr, Larry Hinderager, J. R. Simplot Co.,
     Pocatello, Idaho, May 18, 1979.

4.   Personal communication with Mr. Joseph G. Peters, New Wales Chemicals,
     Inc., Mulberry, Florida, May 29, 1979.

5.   Personal communication with Mr. Thomas  Faulkner, Swenson Evaporators/
     Division of Whiting Corporation, Harvey, Illinois, May 30, 1979.

6.   Background Information for Standards of Performance:  Phosphate Fertilizer
     Industry EPA-450/2-74-019a,  October 1974.
                                     93

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                   DIAMMONIUM PHOSPHATE PLANTS - SUBPART V
                              §60.220 - 60.224
Introduction

     Granular diammonium phosphate plants regulated In this part are defined
as any plant manufacturing granular diammonium phosphate by reacting phosphoric
acid with ammonia.  Affected facilities within each plant Include any combina-
tion of reactors, granulators, dryers, coolers, screens, and mills.  Emissions
of total fluorides are limited to 30 g/metrlc ton (0.06 Ib/ton) of equivalent
P2®5 feed (the quantity of phosphorous, expressed as phosphorous pentoxlde,
fed to the process).  Sources constructed, reconstructed or modified after
October 22, 1974, are subject to the regulation.

Process Description

     Two possible methods exist for the manufacture of diammonium phosphate
(DAP); one results In run-of-pile product (large pellets), made In a TVA cone
mixer, which cures In a storage pile and Is then granulated; the other results
In a slurry which Is granulated In an ammonlator or granulator.  Since the
latter (slurry) process Is the most likely to be employed In new facilities,
the following process description, flow diagram, and startup operations will
apply to this type.

     The production of DAP (high-analysis fertilizer) results in different
compositions depending on the type of phosphoric acid used in the process.  If
phosphoric acid made by burning elemental phosphorous in an electric furnace is
used, the resulting fertilizer composition is 21-54-0 (21 percent total nitrogen,
54 percent available phosphate as phosphorous pentoxlde, and 0 percent soluble
potash as ^0).  If wet-process phosphoric acid is used, the resulting analysis
is 18-46-0.   A flow diagram of a typical plant is illustrated in Figure 21.

     Vapor or liquid anhydrous ammonia and phosphoric acid are proportioned to
an agitated atmospheric tank (preneutralizer) to maintain a ratio of 1.3:1.5
moles of ammonia per mole of phosphoric acid.  The exothermic reaction that
takes place results in the evaporation of approximately one tenth of the
product as water.   The slurry obtained from the preneutralizer flows into the
ammonlator-granulator at about 121°C (250°F).  As it is distributed over the
bed of solid material, it reacts with additional ammonia fed through a distribu-
tor pipe beneath the bed to complete the reaction to a mole ratio of 2.0 (diam-
monium phosphate).  Material from finished product screening is recycled to
the ammoniator along with additional solid raw materials to aid in moisture
control.  The moist granules exiting the ammoniator proceed through an oil-
or gas-fired concurrent rotary dryer where moisture content is lowered to about
                                      94

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     i«r
        NITHATE ,WKA,
AMD OTMC*  3OLID3
VAPOR OH
       ,t
 Arm
                   LJ
Li
                                                                   •ATM
                                              CYCLMK    ctcuam

                         3H
    raCWEUTNAUim
                          AM
                          PUEL
                                          ORTEII
                                                                      krWASTE
                                                           1A
                                                         BUCKET
                                                              nun
                                                                  *i
                                                                               »ULK
                                                                              STOMMC
                                                                      1 f
                                                                     •*•.»>,

                                                                   COOLER
                                                        SHlPPlttft C	ftAB^IHfi
     Figure 21.  Process  flow diagram for dianmonium phosphate production1*.

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 1 percent.  Dry product is then cooled by a countercurrent  flow  of  air In a
 rotary cooler and screened with coarse material being returned to the  ammoniator.
 In some plants, hot screening is employed such that cooling Is achieved prior
 to storage and shipping.  Exhaust gases from the dryer  (and cooler) pass through
 cyclones or wet scrubbers for partlculate removal while effluent from  the  ammo-
 niator are usually scrubbed with incoming phosphoric acid prior  to  discharge
 to the atmosphere.

 Pre-Startup Operations

      As depicted in Figure 21,  the process consists of a wet end (prior  to
 ammoniator) and a dry end (ammoniator and downstream).   All equipment on the
 wet end is water-batched to check for leaks  and proper valve operation.  All
 pumps,  electrical connections,  and instrumentation are thoroughly checked and
 evaluated with respect to proper  operation and  calibration.

      The granulator,  dryer,  and cooler (if used)  are all inclined slightly and
 must be mechanically  checked  for  proper  rotation  and tracking.   The  gear box
 and driving mechanism must mesh properly and operate without excess  noise or
 heat.   This can take  from 2 hours  to  2 weeks.

      The dryer furnace would  undergo  preliminary  operations  similar  to  those
 described  previously  for fossil fuel  boilers.

      Once  all  equipment is installed  and verified  for proper installation, con-
 nections and mechanical operation,  the plant is operated dry with recycle ma-
 terial  (rather than slurry) to check  conveyors  (recycle, belt,  and elevator)
 for binding prior  to  initial  charging.  All  other  equipment  is  also  run dry
 prior to initial charging.

 Startup Operations

      Once  all  process  equipment has been operated with dry recycle material and
 has been shown  to operate  reliably, the preneutralizer (or reactor)  is  charged
 with ammonia, water, and phosphoric acid and the process is  begun.   Initial
 charging varies depending  on the size  of Che plant but usually would require
 45-91 metric tons (50-100  tons) of DAP.

     The key, controlling  factor with respect to proper operation of the  entire
 plant is the particle size of the  finished material.  Fines  are recycled  to  the
 granulator while oversize material is recycled to the mills  and back to  the
 granulator.  Recycling is important to the process and too much on-size material
 can also be a problem.  Normal recycle to product ratio is 3:1.   Throughout  the
 life of the plant,  the operators are constantly trying to find the one limiting
 piece of equipment which could affect the entire facility's  capability.

     Startup is best defined as  the time  of initial firing of the furnace and
 charging of the preneutralizer with ammonia and  phosphoric  acid.   This would
be the first time for potential  fluoride  emissions and would  come  after all
equipment has  been thoroughly  debugged.  The  controlling  factor  would be the
specific gravity of the slurry.  It would normally take  about 2  to 6  hours to
sufficiently heat and  charge  the system and full production rate could be
achieved in 2  weeks.   A plant  acceptance  run  would  usually  be performed  shortly
thereafter.

                                      96

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                                 REFERENCES
1.   Personal communication with Mr. George Chambers, Beker Industries, Inc.,
     Hahnville, Louisiana, April 19, 1979.

2.   Personal communication with Mr. Schwarer, Brewster Phosphates, Luling,
     Louisiana, April 6, 1979.

3.   Background Information for Standards of Performance:  Phosphate Fertilizer
     Industry.   EPA-450/2-74-Ol9a.   October 1974.

4.   Shreve,  R. Morris,  Chemical Process Industries, 3rd Edition, McGraw Hill
     Book Co.,  1967.

5.   Personal communication with Mr. James  C.  Daniel, U.S.S. Agrichem/Dlvision
     U.S.S.  Steel,  Fort  Meade, Florida,  May 18, 1979.
                                    97

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                     TRIPLE SUPERPHOSPHATE PLANTS - SUBPART W
                                §60.230 - 60.234
 Introduction
      A triple superphosphate plant is defined under this subpart as any facility
 manufacturing triple superphosphate (TSP)  by reacting phosphate rock with phos-
 phoric acid.   Affected facilities include  any combination of mixers, curing
 belts (dens), reactors,  granulators,  dryers, cooler^ screens, mills, and
 facilities which  store run-of-pile TSP (any triple superphosphate that has not
 been processed in a  granulator  and is composed of particles at least 25 percent
 by weight  of  which (when not caked) will pass through a 16 mesh screen).  Emis-
 sions of  total fluorides are limited  to 100 g/metric ton (0.20 Ib/ton) of
 equivalent P2°s feed (the quantity of phosphorous, expressed as phosphorous
 pentoxide, fed to the process).   Sources constructed, reconstructed or modified
 after October 22, 1974,  are  subject to the regulation.

 Process Description

      A typical flow  sheet for TSP  production ia  given in Figure 22.   Triple or
 concentrated  superphosphate  can contain from 44  to 51 percent available P2°5>
 as compared to 16 to 20  percent P205  available in normal superphosphate.   Ground
 phosphate  rock containing 75 percent  BPL (bone phosphate of lime or  tricalcium
 phosphate), reacts with  phosphoric acid in the granulator (also called a blunger
 and similar to a  pug mill) with steam, water and  recycled fines.  Recycling is
 used to control moisture  and temperature for proper granulation.  The  phosphoric
 acid is preheated (only  if made by the wet-process)  and  fed to  the granulator
 from beneath  the  bed  through a perforated  pipe.   The granules formed then  over-
 flow the dam  at the  end of the granulator  and  pass  into  a rotary  cooler  (or
 bucket elevator to the screening area if the cooler  is installed  further down-
 stream) .   Exhaust gases pass through a cyclone where  collected  dust is recycled
 to the blunger.   The product is screened with  oversize material directed to a
 mill and recycled back to the granulator.    In  plants utilizing hot screening,
 the cooler  can be located downstream of the  preliminary storage bin and prior
 to final product  storage and shipping.  Exhaust gases from  the granulator  and
 cooler are  scrubbed with water to remove silicofluorides.

 Pre-Startup Operations

     Because of the similarity between diammonium phosphate and triple super-
 phosphate production, the preliminary  equipment checking operations are basically
 the  same.   Equipment is rotated to ensure  proper mechanical operation, align-
ment, and acceptable vibration.   Electrical interlocks are checked for proper
 shutdown sequences such that  serious downstream spills can be prevented in  the
 event of  upstream  equipment failure.


                                      98

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                                                            WATER
                                                                                                  WATER
ID
IO
          PHOSPHATE  ROCK
                       Figure 22.   Flow diagram for triple superphosphate manufacturing process1

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     All liquid handling equipment are hydrostatically tested (prior to delivery
to the plant) at guaranteed pressures while the plant would test these systems
at design operating levels.  These pieces of equipment (scrubbers or acid pre-
heaters) are also filled with water to check for leaks and to verify that
instrumentation and monitoring equipment are functioning properly.

     Other procedures undertaken prior to plant startup would include:

     •    check plant for safety equipment, emergency lights, adequate
          egress, handrails, fire extinguishers, etc.;

     •    review operating procedures to establish best means of
          operation;

Startup Operations

     Startup would be best defined as the initial charging of the wet system;
i.e., phosphoric acid to the preheater and water to the scrubbers.   Initial
operations take place at half load and,  in cases where all components are
properly designed and there are no major equipment failures,  rated capacity
can be achieved in 8  hours.   Abnormal circumstances can extend this time
period to 6 to  8 weeks.
                                     100

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                                  REFERENCES
1.   Personal Communication with Mr. Robert H. Dewey, W.R.  Grace Company,
     Bartow, Florida, April 9, 1979.

2.   Personal Communication with Mr. Harold W. Long, Jr.,  Agrico Chemical
     Company, Mulberry, Florida, April 27,  1979.

3.   Background Information for Standards of Performance:   Phosphate Fertilizer
     Industry.   EPA-450/2-74-019a.   October, 1974.

4,   Shreve, R.  Norrls, Chemical Process Industries, 3rd Edition,  McGraw-Hill
     Book Company,  1967.
                                      101

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          GRANULAR  TRIPLE  SUPERPHOSPHATE STORAGE FACILITIES - SUBPA1T X
                                §60.240 - 60.244
 Introduction

      This  aubpart regulates any facility curing or storing granular triple
 superphosphate  (GTSP).  Affected facilities include any combination of storage
 or  curing  piles, conveyors, elevators, screens, and mills.  Emissions of total
 fluorides  are limited to 0.25 g/hr/metric ton  (5 x 10"1* Ib/hr/ton) of equiva-
 lent  P20s  stored (the quantity of phosphorous, expressed as phosphorous pent~
 oxide, being cured or stored).  Sources constructed, reconstructed or modified
 after October 22, 1974, are subject to the standard.

 Process Description

      After manufacture, GTSP is transferred to the storage building for curing
 (completion of reaction).  Curing serves to increase the physical strength of
 the granules and the availability of P20s as plant food by further promotion
 of the reaction between the phosphoric acid and phosphate rock.  The activities
 within the storage plant are Illustrated in Figure 23.  Granular product is
 transferred to a storage pile where curing takes place and from which fluorides
 evolve.  Front-end loaders move the product to the screening area from which
 oversize material is rejected, pulverized, and returned to the screen; under—
 size  material is returned to the production plant; and on-grade material is
 delivered  to shipping.

 Pre-Stajrtup Operationa

     Mechanical equipment which must be checked within the storage facility
 are very much similar to the dry segments of the diammonium phosphate and
 triple superphosphate plants.   Conveyors, screens, mills, and elevators are
 all operated dry, prior to delivery of material, to verify proper installation
 and mechanical operation and to check for excessive vibration and correct
alignment  of gear-driven components.

 Startup Operations

     The operation  of the GTSP storage facility is obviously dependent upon the
operation  of the production plant.   Therefore, startup would be best defined
as the first delivery of product to the storage pile from the GTSP plant.  Pro-
blems that might occur with equipment downstream of the storage pile could
result in a shutdown and subsequent re-startup of both facilities, and there-
fore, enforcement personnel would have to closely follow the operations of
both facilities.
                                      102

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  PROM
PMOOUCTKM
                                                                               SHIPPING
                                                                                     TO
                                                                                ATMOSPHERE
                                                                                     t
              Figure 23.  Granular triple superphosphate storage plant3.

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                                  REFERENCES
1.   Personal Communication with Mr.  Robert H.  Dewey,  W.R.  Grace Company,
     Bartow,  Florida,  April 9,  1979.

2.   Personal Communication with Mr.  Harold W.  Long, Jr.,  Agrico Chemical
     Company, Mulberry,  Florida, April  27,  1979.

3.   Background Information for Standards of Performance:   Phosphate Fertilizer
     Industry.   EPA-450/2-74-019a.  October 1974.
                                     104

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                       COAL PREPARATION  PLANTS  - SUBPART Y
                                §60.250  -  60.254
 Introduction

     The NSPS for this category encompasses any  facility of greater than 182
 metric tons (200 tons) per day process weight which prepares coal by breaking,
 crushing, screening, wet or dry cleaning, or thermal drying.  Affected facili-
 ties include thermal dryers, pneumatic coal - cleaning equipment, coal process-
 ing and conveying equipment, -coal storage systems, and coal transfer and load-
 ing systems.  Performance standards are promulgated for particulate matter
 from these facilities.  Thermal dryer emissions are not to contain greater than
 0.070 g/dscm (0.031 gr/dscf) or exhibit 20 percent opacity or greater.  Pneu-
 matic coal cleaning equipment emissions are not to exceed 0.040 g/dscm
 (0.018 gr/dscf)  or exhibit 10 percent opacity or greater.  An emission limit
 of less than 20 percent opacity Is promulgated for discharges from any coal
 processing and conveying equipment,  coal storage systems, and coal transfer
 and loading systems.  Sources constructed, reconstructed or modified after
 October 24, 1974, are subject to the regulation.

 ProcessDescription

     Coal preparation plants crush,  screen,  and dry run-of-mine coal.   Secondary
 crushing Is sometimes needed at preparation plants to ensure good separation of
 coal from impurities.  Classifying screens separate coal by size and route it to
 various coal cleaning unit operations.   These unit operations include  drying,
 pneumatic coal conveying,  and breaking  or crushing.  Emission control  from these
 processes is usually achieved with baghouses and wet suppression systems.

 Pre-Startup Operations

     There are a number of operations undertaken prior to startup.   These opera-
 tions are necessary to ensure proper operation of equipment and to prevent
 damage to machinery.

     For driers, a check of the bearings is  made to determine if overheating
 occurs.   If no problems are encountered, the drier is ready for on-line opera-
 tion.   Other equipment is  checked to determine if it is operating properly and
 is then ready to be placed on-line.

 Startup Operations

     Startup is  best defined as the day the  first shipment of coal is  fed through
 the crusher.  Conversations with equipment manufacturers and consultants indicate
 that once the equipment is installed and checked process operations can be
 initiated immediately.  Typical times for installation of equipment to attain-
ment of full operational level are as follows:

                                      105

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                          Equipment              Time
                     Crushers                 2 weeks,
                     Driers                  1-4 days,
                     Total Plant  (large)      1-3 months.

     Based on the aforementioned  data,  commencement of  process  operations  is
a reasonable date for startup.  Testing at  full  operational  level  can be achieved
within 180 days of this date with no  anticipated problems.
                                     106

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                                  REFERENCES
1.   Personal communication with Mr. D. Graveman, American Pulverizer Company,
     St. Louis, Missouri.  12 March 1979.

2.   Personal communication with Mr. Benning, Dravo Corporation, Philadelphia,
     Pennsylvania.  13 March 1979.

3.   Personal communication with Mr. Carpenter, Jeffrey Manufacturing Co.,
     Columbus, Ohio.   12 March 1979.

A.   McCandles, L.C.  and R.B.  Shaver.   Assessment of Coal Cleaning Technology:
     First Annual Report.  EPA-600/7-78-150, U.S. Environmental Protection
     Agency, Research Triangle Park, North Carolina,  July 1978.
                                     107

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                  FERROALLOY PRODUCTION FACILITIES - SUBPART Z
                               §60.260 - 60.266
 Increduction

      The  Standards of Performance for Ferroalloy Production Facilities affect:
 (1)  electric submerged arc  furnaces which produce silicon metal, ferroeilicon,
 calcium silicon, silicomanganese zirconium, ferrochrome silicon, silvery Iron,
 high—carbon ferrochrome, charge chrome, standard ferromanganese, ailicomanganese,
 ferromnnganese silicon, or  calcium carbide; (2) and dust handling equipment.
 The  pollutants regulated are participates and carbon monoxide.

      OwnerH or operators are not permitted to discharge from any electric sub-
 merged arc furnace any gases into the atmosphere which: (1) exit from a control
 device and contain particulate matter in excess of 0.45 kg/MW-hr (0.99 Ib/MW-hr)
 while silicon metal, ferrosilicon, calcium silicon, or sllicomanganese zirconium
 in being  produced, (2) exit from a control device and contain particulate mat-
 ter  in excess of 0.23 kg/MW-hr (0.51 Ib/MW-hr) while high-carbon ferrochrome,
 charge chrome, standard ferromanganese, silico-manganese, calcium carbide,
 ferrochromc silicon, ferromanganese silicon or silvery iron is produced,
 (3)  exit  from a control device and exhibit 15 percent opacity or greater,
 (4)  exit  and escape the capture system and are visible without the aid of
 instruments (applies only during periods when flow rates are being established),
 (5)  escape the capture system at the tapping station and are visible without
 the  aid of Instruments for more than 40 percent of each tapping period.  There
 are  no limitations on visible emissions when a blowing tap occurs (requirements
 apply only during periods when flow rates are being established).

      Dust handling equipment emissions are limited to lees than 10 percent
 opacity.  Carbon monoxide from any electric submerged arc furnace Is limited
 to less than 20 percent by volume (dry basis),  A continuous monitoring sys-
 tem  is required to monitor opacity of emissions discharged from the control
 device•

      Sources constructed, reconstructed or modified after 21 October 1974 are
 subject to the regulations.

Process Description

      Ferroalloy in a material consisting of iron and one or more other metals.
 Ferroalloys are used in steel production as alloying elements and deoxidants.
There are three types of ferroalloys:  silicon-based;  manganese-based; and
chromium-based alloys,   There are four major procedures used to produce ferro-
alloy:  blast  furnaces,  electrolytic deposition, alumina silico-thermlc process,
and electric smelting.   However,  the primary system used is electric smelting.

                                      10B

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 Seventy-five  percent  of  all  ferroalloys  are produced in electric smelting fur-
 naces,  of which  electric submerged-arc open type  is  the oldest,  simplest and
 most widely used.   The alloys  are made in the  electric  furnaces  by reduction
 of  suitable oxides.   For example, in  the  production  of  ferrochromium,  the charge
 may consist of chrome ore, limestone, quartz coal, wood chips, and scrap iron.
 The production of  ferroalloy requires a number of steps from materials  handling
 to  smelting to shipment.  Figure 24,  illustrates a schematic diagram of the
 system  Involved.

     Experts  In  the electric submerged arc  furnace Industry Indicated  that there
 are no  new plants presently under construction and that there are  none  planned
 for the next  5 to 10  years.

 Pre-Startup Operations

     The pre-startup  operation of a ferroalloy  facility involves the coordina-
 tion of numerous systems.  Each unit must undergo Its own pre-startup checks and
 startup procedures before It can be Integrated with  the rest of the system.
 Very often minor malfunctions and defects in units are  the primary reason for
 delays  In meeting the startup and maximum production dates.  Some of the units
 which may have problems are crushers, scales,  feeders,  castings and pollution
 control units.  At this time in the pre-startup procedure, most of  the  units are
 checked-out without a material load.  The primary unit  used in the production
 of  ferroalloy is the electric submerged arc furnace.   The furnace ranges  in
 size from 6.1 to 12.2 meters (20 to 40 feet) in diameter with a height  of
 4.6 to 6.1 meters (15 to 20 feet).   The furnace has  a 5 cm (2 in.) thick  steel
 shell and is lined with brick refractory.  Between the  refractory brick and
 the steel shell is a carbon liner.   Electrical power transmitted through
 electrodes bearing down on resistant coke provides the  heat for smelting in
 the furnace.   Systems and components that are given  special attention relative
 to  the electric furnace pre-startup operations are:   water cooling, water
 treatment,  roof and wall  structures, air  pollution controls, electrode
 rigging, electrode slipping and backing mechanisms,   tapping, lattle, crane
movement,  and all electrical,  mechanical  and hydraulic  subsystems.

     The first major step in pre-startup  of an electric submerged arc furnace
depends  on the type of electrodes  used.   Internationally, there are two types
 of electrodes that may be used In  producing ferroalloys:  prebaked and self-baked.
 The pre-baked electrode,  which is  usually manufactured  elsewhere, is a hard
 rod-shaped baked carbon/silicon body ranging in size from 0.3 to 61 cm  (1/8 to
 24  in.)  in diameter and lengths up to 244 cm (96 inches).  The self-baked
 electrode is a pasty mixture of carbon and silicon which is baked into  a hard,
 rod-shaped carbon body within the  electric submerged arc furnace (this report
 examines only the self-baked electric submerged arc  furnace because they are
 primarily used In the United  States).

     The first pre-startup step Is the baking of the pasty carbon-silicon mix-
 ture into a hard, rod-shaped  body.   This  step Is called bake-in.   The carbon
material Is contained In  a thin gauge, hollow electrode steel cylinder 15 to
 18 meters (50 to  60 feet) in height.  At  take-in,  a  pre-baked electrode Is
 Inserted Into the cylinder followed  by a  homogeneous mixture composed of coal,
metallurgical  coke, lampblack,  coal  tar pitch,  and petroleum coke.  The furnace


                                     109

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                                     WATER
                                     COOLED
                                     HOOD
                                                         TO  BAGHOUSE OR
                                                         ______  SCRUBBER
                     Cu;'
ZF1
   I  P.  !!
                                                         ELECTRODE
«io»D'i»<; «S'^BT»?HT •?«>(""<•»-,{ :»usM'nc «trc« FEEDING
I DUST
KLTM
. :i: , E
CKTM |

Figure 24.   Schematic diagram of the ferroalloy production process.7

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 ia  then  loaded with a  0.2  m3  (55  gallon)  drum of coke (the conductive material),
 The electrode cylinder and content  is  lowered into the coke drum bearing down
 with electric power.   The  system  electrodes  are  energized with low voltage,
 wherein  heat is  created by electrical  resistance from the coke.   This heat
 bakes the carbon paste in  the upper portion  of the cylinder.   Voltage is in-
 creased  and more coke  is added, thus increasing  the furnace temperature and
 baking more of the  carbon  mixture in the  column.   The bake-in will continue
 until about 4.6  meters (15 feet) of carbon mixture in the column is baked to
 a hard carbon body.  As the pre-baked  electrode  is consumed (-—2.5 cm or 1 in.
 per  hr), the self-baked electrode will slip  down bearing  on the  coke.   More
 carbon mixture would then  be added  to  the column to replace the  consumed por-
 tion of  the electrode.   Once the bake-in  is  completed,  pre-baked electrodes
 are  not  used again.  Pre-baked electrodes are  only used during bake-in
 (startup).  If pre-baked electrodes  are not  used during bake-in,  the  entire
 electrode column  is filled with carbon paste and baked  with an auxiliary fuel
 (oil or  gas).  The  entire bake-in takes 2 weeks  time  while  curing the  furnace
 takes  another 2  to  3 weeks, and heating the  furnace to  operating temperatures
 takes  about 1 to  2 weeks.  During the bake-in, curing,  and  heatup,  the  furnace
 will normally be  shutdown  5 to 10 times for  repair  of malfunctions, defects
 and  especially to tighten  the bus bar.   Shutdown and  startup will only  take
 a few  hours unless  there is a major malfunction.   The total pre-startup  opera-
 tion may consume  a  5 to  7 week period.

 Startup Operations

     Up to this  time, no metal has been introduced  into the furnace.  Upon
 reaching operating temperatures of 2760 to 3316°C  (5000 to 6000°F), metal is
 slowly introduced to the furnace.   The  furnace is stabilized and  then more
 charge is added.   The technique will continue until the furnace has attained
 rated capacity.   If everything operates smoothly, the furnace  should reach
maximum production in six months.   However,  in ferroalloy production, there
 are numerous units involved where  many  problems can develop.  Experience has
 shown that most  plants take 6 to 12  months to reach maximum production.  Two
major problems  are the integration of all units and the training of operators.
 If any units,  systems or operators are  not running at rated capacity, the
maximum production rate cannot be  reached.  Most  furnaces operate at 50 percent
maximum production the first year  and in succeeding years production will
 increase to about 90 percent.   The first year of  operation is usually plagued
with numerous malfunctions and breakdowns.  The official startup date for an
 electric submerged arc furnace should begin when  metal is first introduced
 into the furnace.
                                    Ill

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                                  REFERENCES
1.   Personal Communication with Dr.  C.R.  Allenback,  Union Carbide,  Niagara
     Falls,  New York,  May 9, 1979.

2.   Personal Communication with Dr.  R.  Persons,  Union Carbide,  Niagara Falls,
     New York,  May 9,  1979.

3.   Communication with Foote Mineral Company,  Exton,  Pennsylvania,  May 8,  1979.

4.   Communication with Paul Blum Company, Inc.,  Buffalo,  New York,  May 8,  1979.

5.   Personal Communication with Dr.  Watson,  Ferroalloy Association, Washington,
     D.C., May 9",  1979.

6.   Personal Communication with Mr.  John  Persons, Lectromelt, Pittsburgh,
     Pennsylvania,  May 8,  1979.

7.   Dealy,  James and  Arthur Killin,   Engineering and  Cost Study of  the
     Ferroalloy Industry,  EPA 450/2-74-008.   U.S. Environmental  Protection
     Agency.   1974.
                                     112

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          IRON AND STEEL PLANTS:  ELECTRIC ARC FURNACES - SUBPART AA
                               §60.270 - 60.275
Introduction

     Affected facilities under this subpart include the electric arc furnace
(EAF) and associated dust-handling equipment.   Electric arc furnace means any
furnace that produces molten steel by melting charge material with electric
arcs from carbon electrodes.  Dust-handling equipment means any equipment used
to handle particulate matter collected by an EAF control device.

     The emission standard promulgated under this subpart limits particulate
matter discharge from an EAF control device to 12 mg/dscm (0.0052 gr/dscf).
In addition, control device exhaust stacks shall not exhibit 3 percent opacity
or greater.   Emissions from the dust-handling equipment shall not be >^ 10
percent opacity.

     With respect to the EAF melt shop, emissions from the shop are limited to
0 percent opacity except during:

     •    charging periods, when the shop opacity may be greater
          than zero but less than 20 percent.

     •    tapping periods, when the shop opacity may be greater
          than zero but less than 40 percent.

Where the EAF capture system is operated with the shop roof closed during charg-
ing and tapping, and emissions to the atmosphere are prevented until the roof is
opened after completion of the charge or tap, shop opacity standards shall apply
when the roof is opened and shall continue to apply for the time defined by the
charging and/or tapping periods.   Continuous opacity monitoring of emissions
from the control device is required.  Affected facilities constructed, recon-
structed or modified after October 21, 1974, are subject to the requirements of
this subpart.

Process Description

     Electric arc furnaces (EAFg) for the production of steel have been in use
since 1906.   The recent demand for higher quality alloy and stainless steels
is responsible for increasing use of EAFs.  It has been estimated that 20 per-
cent of the steel produced in the U.S. in- 1976 was made in EAFs and as open
hearth units are shut down, EAF units will see increasing use.
                                      113

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     EAFs  utilize  electric current  as a source  of heat  to melt scrap metal.
The process begins when scrap metal and alloys  are  charged to the furnace.
Following  charging the electrodes are lowered into  the  charge to  start  the
initial "horedown" period.  During  boredown, a  pool of  molten metal  is  formed
on the surface of  the scrap charge.  From this  time on,  the charge is melted
by a combination of heat from the arc, heat radiated  from the bottom of the
venae! | nncl by the resistance of the scrap to the current.   Occasionally,
the boredown period is interrupted  and additional scrap and/or fluxing  agents
are added  to the mixture.  When the charge is completely melted,  the steel
and slag (the solid waste formed during melting) are  tapped into  ladles and
pots respectively.  Molten steel is then either further  processed  to produce
stainless  steel, poured into ingot molds or sent to a continuous  caster.

Pre-Startup Operations

     There are several operations involved in the pre-startup  process for elec-
tric arc furnaces.  Mechanical and electrical equipment  must be checked  to
ensure that they are fully operational.   Lastly, the  furnace  refractory  is
preheated and checked.  Once these steps are completed,  the furnace  is  ready
for operation.

StartupOperations

     Initial startup involves charging the furnace and initiating boredown.
The time required to attain maximum production depends on furnace alze.  Con-
versations with industry personnel indicate that for most furnaces full
production level can be achieved in 6 months.   Based on  this,  the startup date
la best defined as the time of the first furnace heat.  However, if during
startup operational problems are encountered which significantly alter normal
cycle times, representative performance test data might be unattainable until
the problems are straightened out.
                                     114

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                                  REFERENCES
1.    Personal communication with Mr.  J.  Haley,  Pullman-Swindell, Pittsburgh,
     Pennsylvania.   13 March 1979.                   ,

2.    Personal communication with Mr.  J.  Galbreath,  Whiting Corp,,  Harvey,
     Illinois.   13  March 1979.

3.    U.S.  Steel.  The  Making,  Shaping and Treating  of  Steel.   Herbick and
     Held, Pittsburgh, Pennsylvania.   1971.
                                     115

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                        KRAFT PULP MILLS - SUBPART BB
                                §60.280 - 60.285
 Introduction

     The facilities of a kraft pulp mill covered under this subpart are:  di-
 gester system, brown stock washer system, multiple-effect evaporator system,
 black 1 Icjuor oxidation system, recovery furnace, smelt dissolving tank, lime
 kiln, and condenaate stripper system.  In pulp mills where kraft pulping is
 combined with neutral sulfite semi-chemical pulping, the provisions of this
 aubpart are applicable when any portion of the material charged to an affected
 facility is produced by the kraft pulping operation.  Facilities constructed,
 reconstructed or modified after September 24, 1976, are covered by the
 regulation.

     A particulate emission limit of 0.10 g/dscm (0.044 gr/dscf) corrected to
 8 percent oxygen and an opacity of less than 35 percent have been set for the
 recovery furnace.  Emissions from the smelt dissolving tank are limited to
 0.1 g/kg black liquor solids (dry weight) or 0.2 Ib/ton black liquor solids (dry
 weight).   For the lime kiln, the limit is 0.15 g/dacm (0.067 gr/dscf) cor-
 rected to 10 percent oxygen when burning gaseous fossil fuel and 0.30 g/dscm
 (0.13 gr/dacf) corrected to 10 percent oxygen, when burning liquid fossil fuel.

     Total  reduced Bulfur (TRS) means the sum of the sulfur compounds-hydrogen
 sulfide,  methyl mercaptan, dimethyl siilfide, and dimethyl disulfide - which are
 released  during the kraft pulping operation.  An emission limit of 5 ppm of
 TRS by volume on a dry basis corrected to 10 percent oxygen has been established
 for the digester system, brown stock washer system, multiple-effect evaporator
 system, block liquor oxidation system and condensate stripper.  This emission
 limit remains in effect unless one of the following conditions are met'.  (1) the
 gases are combusted in a lime kiln, (2)  the gases are combusted in a recovery
 furnace,  (3) the gases are combusted with other waste gases in an incinerator
 or other  device not subject to the standard and are subjected to a minimum
 temperature of 649°C (1200°F) for at least 0,5 second,  (4) it has been demon-
 strated to  the administrator's satisfaction that incineration of TRS from the
 black liquor oxidation system or brown stock washer system is technologically
 or economically not feasible, or (5) the digester,  brown stock washer, conden-
 sate stripper or black liquor oxidation  system are controlled by a means other
 than combustion whereby TRS emissions do not exceed 5 ppm by volume on a dry
bflnia corrected to the actual oxygen content of the untreated gas stream,

     Emission limits of 5 ppm and 25 ppm TRS by volume on a dry basis, cor-
 rected to 8 percent oxygen have been established for any straight and cross
 recovery  furnaces respectively.   For the smelt dissolving tank, the TRS emis-
sion limit  has been set at 0.0084 g/kg black liquor solids (dry weight) or

                                     116

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  0.0168 Ih/ton  liquor solids  (dry weight)  .  Total  reduced  sulfur  emission
 limits from the lime kiln have been set at 8 ppm by volume on a dry  basis,
 corrected to 10 percent oxygen.

     Continuous monitoring requirements apply to recovery furnace opacity and
 to TRS emissions from lime kilns, recovery furnaces,  digester systems, brown
 stock washer systems, multiple-effect evaporator systems, black liquor oxida-
 tion systems and condensate stripper systems.

 Process Description

     The first step of kraft pulping is to prepare the wood for cooking.  Logs
 are debarked,  chipped and screened prior to being fed to a digester.  Some
mills will operate their own wood processing facilities, whereas others will-
 purchase wood chips from an external source.   The wood chips placed  in the di-
 gester are cooked in a "white liquor," a water solution of sodium sulfite
 (Na-jS) and sodium hydroxide (NaOH),  at a temperature of 170 to 175°C (338 to
 347°F) and pressure of 689 to 931 kPa (100 to 135 psi).  The white liquor chem-
 ically dissolves the lignin of the wood, freeing the cellulose fibers.   The
cooking process, which can be batch  or continuous, usually lasts from 2 to
3 hours.   At the completion of the cook, the charge is blown into tanks to
release steam and other gases.  The  cellulose (pulp) is then separated from the
spent cooking liquor by filtration.   At this point, the pulp is referred to as
brown stock and the spent cooking liquor is called weak black liquor.  After
filtration,  the brown stock is washed with water and passed through knotters,
rifflers and screens which sieve out small pieces of uncooked wood.   Once
screened, the pulp is filtered and sent on to thickeners.  From here, the pulp
can go to a bleach plant or to paper machines for final processing.

     A major portion of the kraft pulping process is devoted to the recovery of
cooking liquor and heat.  The weak black liquor is concentrated in multiple-
effect evaporators to about 65 percent solids and then burned in recovery fur-
naces.  Steam generated by the furnaces Is used for process operations through-
out the plant.

     Basically, there have been only two types of recovery furnaces used in the
kraft pulping industry:   the direct-contact evaporator system and the more re-
cent indirect-contact system.   The former type requires the oxidation of the
concentrated black liquor prior to combustion to reduce TRS emissions.   One
reference source contacted stated that most new mills being built today arid in
 the future will be using the indirect-contact evaporator system.

     The residue resulting from burning the black liquor, called smelt, is dis-
solved in-water to form "green liquor," an intermediate solution used to regen-
erate white liquor.  Once formed, the green liquor is transferred to a causti-
cizing tank where quicklime (CaO) is added to convert the sodium carbonate
(NaaCOs)  to NaOH.   The formation of  NaOH completes the white liquor regen-
erative cycle.   The calcium carbonate (CaCOa) slurry (40 to 45 percent water),
generated during the causticizing process, is converted co CaO by calcina-
tion in a rotary kiln.   The CaO is then reused in the process.
                                     117

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      A condensate  stripping system,  employing either air or steam in a strip-
 ping column, may be  used  to control  TRS  compounds  emitted from the digester
 systems nnd multiple-effect evaporators.   TRS compounds  emitted from other
 facilities are  usually  controlled by process  combustion,  condensers, incinera-
 tors,  or absorption  trays.   A general flow diagram of the kraft pulping process
 is  presented in Figure  25.

 Pre-Star tup Operat i ons

     Before being  connected  to form  the contiguous  operation of  a kraft  pulp
 mill,  each affected and nonaffected  facility  is subjected to extensive shake-
 down procedures.   Electrical and instrumentation systems  are thoroughly  checked
 before any piece of equipment is actuated.  Process  equipment  is  examined  for
 proper installation, clearance, and  rotation.  Transfer  lines  are checked  for
 free passage, leaks, and correct distribution.  In addition, pieces  of equip-
 ment which are operated at elevated  temperatures and  pressures ate  tested
 initially for leaks and expansion with hot water and  then with steam, which is
 provided by the power boilers or recovery furnaces  (fired with auxiliary fuel).

     The three most important facilities affected within  a kraft  pulp mill are:
 the  digester systems, recovery furnaces,, and  lime kiln.   Initial  shakedown
 operations for the digesters involves passing hot water through  the  units  (in-
 cluding  the blow tanks)  to check seals and as a preliminary rinse.  Next,
 steam  is passed through the digesters for further cleaning and to  test expan-
 sion joints.   A final shakedown step prior to actual  startup is  to  feed  chips
 and  steam to the digester to simulate a cook.  The partially cooked  chips will
 be  passed to the blow tank to assure proper distribution  and free passage of
 material,  This last step may last [from one to eight hours.          ,
                                   i

     Pre-startup operations of the recovery furnaces are  similar  to  those of
 an  Industrial boiler.  These procedures include cleaning  the inner walls of the
 furnace; boilout (which removes grease and other deposits from the water and
 steam  tubes);  and testing of components with respect  to thermal expansion, mech-
 anical stresses, corrosion resistance, structural soundness, warping, and leak-
 age.   Process controls, sensors,  monitors, loading switching, safety interlocks,
 and  the  steam distribution system are also checked prior  to startup.  In addi-
 tion,  fans and pumps are run, dampers are stroked and burners are test fired.
 All  furnace tests are conducted with auxiliary fuels such as oil or gas.

     The startup of a recovery furnace is subject to codes set forth by  the
 Black Liquor  Recovery Boiler Advisory Board, a self-governing body made up of
 members  from  the kraft pulp mill  industry.  Some of the requirements of the
 board are that certain welds be radiographed to assure integrity, hydrostatic
 pressure tests be conducted and certain safety systems be Installed and
 thoroughly checked  before the furnace is started.   The shakedown period for
 recovery furnaces will normally last from two to seven days.  Electrostatic
 precipitatora  ore typically used  to  control particulate emissions from recovery
 furnaces, whereas absorption-type scrubbers are used to control reduced sulfur
compounds.
                                    118

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        NONCONOENSAtLES
WOOD
WHITE LIOUOV
INtOH »NOjSr
ENHAUB1
--'
•
WATER
4 WHITE
[ LIQUOR
(RECYCLE TO
DIBESTER)
' VENT OASES
^COMPENSATE |

OIOEBTER
I 6AS
RECOVERY
FURNACE H
SYSTEM g
. *_
, *I
SMELT ^
NBjCOjT NBjB)
4 f
SMELT i
DISSOLVING
TANK
GREEN LIQUOR
i
CAUSTICIZING
TANK

* 	 rTLiLow .x-- — L— ^.^
	 r I'AJ,* X^ ^N^" TO
1 1 SROWN STOCN -^-^JSToVAV!
\/fULP IPULP) SCREENS


WATER
WEAK BLACK LIOUOR f\
NONCONOENSABLES
VENT OASES 4
1

1 ^/UA. MULTIPLE
.LIQUOR CFFKCT
OKIOATIOM EVAfORATOR
CAVV TAN« SYSTEM
LAC* ((OPTIONAL) -. „ -
IOUOR 1
' 1 ' '''

'* VENT OASES
f
ENT _|
CASES CONOENBATE — '
•-* STRIPPER
T TO TREATMENT
1 » POND
ENHAUBT
A OABEB
* "%^*-J* .
• CALCIUM CARBONATE
                         SLURRY
Figure 25.  Flow diagram for Kraft  pulping
            process operations.2
                    119

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      The  pre-startup operations of a kraft pulp mill  lime  kiln are similar  to
 those of  a rotary kiln used  in Che manufacture of  lime.  Once the kiln has  been
 erected and before it is bolted down, various tests are  conducted to  check  its
 alignment and rotation.  Once the kiln passes these preliminary  tests, it is
 secured and rechecked for alignment and rotation.  A  third examination is made
 when  heat IK first introduced to the kiln.

      The most important pre-startup operation of the  kiln  is the seasoning  or
 drying out of the brick refractory lining.  New refractory usually contains
 residual amounts of water which must be driven out before  the lime slurry can
 be  fed into the kiln.  The drying out process is slow, requiring a gradual
 warming of the bricks to prevent cracking or loosening.  The kiln seasoning
 process normally takes 3 to 5 days.

      Once the refractory has been properly seasoned and  the burners and fuel
 supply lines have been checked out, the kiln is ready to receive the lime slurry.
 Lime  kilns operated at kraft pulp mills are usually fired with gas or oil.
 High  energy venturi scrubbers are normally used to control kiln emissions.

 S tartup Operat ions

      The performance of a facility affected by this subpart is dependent upon
 process operations upstream and downstream of the particular unit.  Six major
 operations within a kraft pulp mill are the:   power boilers, digester system,
 recovery furnaces, lime kiln, bleach plant, and paper machines.   The startup
 of a mill requires the operation of at least  the first four of these processes.
 Some mills will not operate bleach facilities nor paper machines.  The power
boilers,  not affected under this subpart,  are the first operations to be brought
 on line.

     Startup of the facilities affected under this subpart is considered to be
when wood chips and white liquor are first fed to the digesters  with the intent
 to produce pulp.   Mill operators contacted stated that it may take from twelve
 to twenty-four hours from the time the first  cook is initiated until recongniz-
able pulp comes out of the thickeners.   The first pulp produced  is not of any
commercial or production value.   Due to the large capital outlay and high daily
operating costs,  this situation will not last long and mill operators will con-
centrate their efforts on fine tuning process equipment in order to  produce
useable pulp as soon as  possible.

     Once the first cook has  been initiated,  it  will take a day  or two before
enough black liquor is produced to fire in the recovery furnace.   Likewise,  it
will be one to two days  after black liquor is first burned before enough lime
slurry is generated from the  causticizing  tank to be fed  into the lime kiln.
Because white liquor  will not be generated from  process operations until  two
to four days after commencement of  the  initial cook,  the  white liquor and
caustic (lime)  must be purchased or  obtained  from some other source  in order
to start  the pulping  process.   Once  the chemical recovery cycle  has  been com-
pleted, it becomes almost  entirely  self-sustaining.  In summary,  it  normally
takes from two to four days after initial  startup;  i.e.,  the introduction of
white liquor and  wood chips into the digester, before all the affected facili-
ties of a kraft pulp  mill  become operational.


                                      120

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     Because kraft pulping is a complex process involving chemical reactions
and several different and sometimes technologically new pieces of equipment,
it may and probably will take longer than 180 days after initital startup be-
fore a mill is operating at or near its maximum production rate.  Several
reference sources contacted stated that it normally takes a year or more for a
mill to reach its maximum production rate.  One source stated, however, that
barring major mechanical failures or the debugging of newly developed process
equipment, a mill could achieve its maximum production rate within 180 days.
Due to the uncertainty in the amount of time required to achieve the maximum
production rate of the affected facility, multiple testing, once prior to
the 180-day limit and once after achieving maximum production capacity may be
required.  It is noted that for certain industrial categories such as kraft
pulp mills, the implementation and enforcement of Section 60.8 of CFR Part 60
may have to be carried out on a case-by-case basis.
                                     121

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                                   REFERENCES


 1,   Environment Reporter, Bureau of National Affairs,  Inc., 1978, New Source
      Performance Standards Subpart BB, Standards of Performance for Kraft Pulp
      Mills.

 2.   Standards Support and Environmental Impact Statement Volume I:  Proposed
      Standards of Performance for Kraft Pulp Mills, 1976.  U.S. Environmental
      Protection Agency Office of Air and Water Management.  Research Triangle
      Park, North Carolina.  EPA-450/2-76-014a.

 3.   Personal Communication with representative of  Technical Association of
      Pulp and Paper Industry, Atlanta, Georgia, April 26, 1979.

 4.   Personal Communication with Mr.  Eddinger, Industrial Studies Branch, U.S.
      Environmental Protection Agency, Research Triangle Park, North Carolina,
      April 27, 1979.

 5.   Personal Communication with Mr.  Landegger, Black Clawson Company,  New York,
      New York, April  27,  1979.

 6.   Personal Communication with Mr.  Dickenson, Babcock and Wilcox, North Canton,
      Ohio, April 27,  1979.

 7.   Personal Communication with Mr.  Nicholson, Weyerhauser Company,  Tacoma,
      Washington, April 27, 1979.

 8.   Personal Communicaiton with Mr.  Elam, Black Clawson Company,  Middietown,
      Ohio, April 27,  1979.

 9.   Personal Communication with Mr.  Salkowski,  Boise Cascade Corporation,
      St.  Helens, Oregon,  April  30,  1979.

10.   Personal Communication with Mr.  Milow,  Combustion  Engineering,  Boston,
      Massachusetts, April 30,  1979.

11.   Personal Communication with Mr.  Sutter,  St.  Regis  Paper Company, Jacksonville,
      Florida,  April 30, 1979.

12.   Personal Communication with Mr.  Derby,  St.  Regis Paper Company,  Monticello,
      Mississippi,  April 30,  1979.

13.   Personal Communication with Mr.  Belas,  Air Enforcement Branch, U.S.
      Environmental Protection Agency,  Region IV,  Atlanta,  Georgia,  April  30,  1979.


                                      122

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14.   Personal Communication with Mr. Tretter, Georgia-Pacific Corporation,
     Atlanta, Georgia, May 2,  1979.
                                    123

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                         GRAIN ELEVATORS - SUBPART DD
                               §60.300 - 60.304
 Introduction

     The sources covered under this subpart are grain terminal elevators which
 have a permanent storage capacity of over 88,100 m3 (2.5 million U.S. bushels)
 and grain storage elevators located at any wheat flour mill, wet corn mill,
 dry corn mill, rice mill, or soybean oil extraction plant which have a perma-
 nent storage capacity of 35,200 m3 (1 million bushels).  The facilities affected
 under this category are:  truck loading and unloading station, railcar loading
 and unloading station, barge and shiploading and unloading station, grain
 dryer, and all grain handling operations.  Standards are set for captured emis-
 sions and uncaptured (fugitive) emissions.

     All captured emissions are passed through a stack or control device prior
 to being emitted to the outside air,  and must meet an opacity standard of
 0 percent.  All captured emissions except those from a grain dryer (column
 dryer or rack dryer) must also meet a particulate standard of 0.023 g/dsctn
 (0.01 gr/dscf).   A fugitive emission opacity limitation has been set at 5 per-
 cent for any Individual truck unloading station, or railcar unloading or load-
 ing station; 0 percent for any grain handling operation; 10 percent for any
 truck loading station; and 20 percent for any barge or shiploading station.
 Sources constructed, reconstructed or modified after August 3, 1978, are subject
 to the regulations.

 Process Description

     Prior to unloading, grain received is graded for quality and dust content,
 and then weighed.  The grain is then  unloaded by direct dumping or conveying
 (e.g., pneumatic, belt, bucket, or chain)  into a receiving hopper and then
 transferred to a surge (garner) bin.   From the surge bin the grain is lifted
 to the headhouse, the top of the elevator.   At the headhouse, the material is
 distributed to one of several storage bins.   Certain incoming grains, however,
may need to be cleaned and dried before they can be stored.

     Cleaning is required when incoming grain contains a high percentage of
 crop soil, weeds, insects, stones and/or stalks.   The first step in cleaning
 (scalping) is to pass the grain through a coarse mesh  screen to remove large
 foreign matter.   Aspiration, the next step,  is carried out to remove the fine
 foreign matter from the grain.   The process  involves directing air crosscurrently
                                     124

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 and  counter-currently  through dispersed falling grain.  The  third and  usually
 final step  is  to size  the grain using a stack of vibrating  screens.   These
 three grain cleaning  steps can be operated separately or  together as  one con-
 tiguous system.  Grain cleaning may occur before and/or after grain storage.

     To prevent spoilage, certain grains, including barley, oats, wheat, corn
 and  sorghum, must be dried to a specified moisture content before they can be
 stored for any length of time.  Drying facilities are used predominately during
 the  harvest season.  An alternative to drying is grain blending, a practice of
 mixing incoming grain which does not have an excessively high moisture content
 with previously dried grain.

     Because grain fermentation and heat  build up may occur in long-term storage
 bins, it becomes necessary to "turn" the  grain to prevent deterioration.  Grain
 turning involves transferring material from the bottom of one bin to the top of
 another bin.  Turning may be required several times a year depending on moisture
 content,  grain temperature,  and the length of time the grain has been stored
 without aeration.

     Prior to grain load out, material will be weighed and cleaned if not done
 90 previously.   The grain is then  transferred from the weigh station to an a-
 waiting carrier vehicle via  telescopic piping.  A general process flow diagram
 for grain terminal elevators is presented in Figure 26.   Particulate emissions
 from affected facilities are typically controlled by mechancial separators and
 baghouses.

 Pre-S tart up Operat ions

     Because of the various  affected unit operations associated with grain ter-
 minal and storage  elevators, many  preliminary shakedown procedures must be
 undertaken.  Checkout procedures common to all the affected facilities are:
 verification of all electrical circuits and connections,  checking clearance of
moving equipment,  bumping of motors and pumps, assuring correct rotation of
 equipment, calibration of scales and instrumentation, and monitoring of air
 pollution control  devices.

     Equipment  checkout procedures unique to unloading,  distribution and load-
 Out facilities  are:  free passage  through transferring legs (e.g.,  pneumatic
belt, or  bucket conveyors),  correct movement and discharge of distributors and
 trippers  of the headhouse and process  control systems.   Equipment employed in
 grain cleaning  are checked out for clearance, alignment,  and free flow of ma-
 terial.   For the dryers,  equipment alignment and rotation, burners,  fuel supply
 lines, air leakage, and temperature and air flow controls are checked out be-
 fore the equipment is actuated.

     Process equipment will  be tested  individually at first, then as integral
 parts of  an affected facility.  Dry runs  will be conducted to make sure pro-
 cess equipment  is  functioning properly before grain is intorduced into the sys-
 tem.  After all equipment has been checked out,  trial runs will be made handling
 grain.  The equipment is tested under  various loads to recheck alignment, rota-
 tion, clearance, free passage of conveying lines, the distribution system, belt
 stretching, and conveyor speeds and to break in air pollution control equipment.
                                      125

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  TRUCK
  TRUCK
RECEIVING
 HOPPER
                    kl
             6RAIN
                         SCALE
                                 f
                                  SUMSE
                                 [GARNER)
                                   • IN
                                                 SCREENS
                                                  AND
                                                 CLEANER
                                                    I
                                                  DRYER
K
O
                                                                w
        DISTRIBUTOR
       AND TRIPPERS
 6RAIN
STORAGE]
 •INS
                                                                         l
          CLEANER
                                                                          I SCALE  |

                                                                  LOADIN6     I    BRAIN
                                                             RAIL CAR
                                                                          IBAME
                 figure 26.  Process flow diagram for grain terminal elevators,
                                                                                         TRUCK
                                                                                        LT  U

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 The  facilities are  tested initially at a minimum load  then gradually brought up
 to or  near design rates.  The grain used for equipment shakedowns may already
 be on-site for a modified source, or for a newly constructed elevator a small
 amount of grain may have to be purchased from a local  farm or country elevator.
 Once each affected  facility has been successfully tested under actual conditions,
 it is  considered to be "ready for business," and capable of receiving grain.
 Pre-Btartup shakedown operations may last from less than 1 to 3 months depending
 on the function of  the subject elevator.

 Startup Operations

     The startup date for each of the affected facilities of a grain terminal
 elevator or grain storage elevator will vary depending on the source's function,
 type of grain received, time of year, and climatic conditions during harvesting.
 Because of inherent flexibility of a grain elevator, some facilities will be
 brought online while others are still under construction, being debugged or
 idle.  Once an elevator starts receiving grain for processing, or export, the
 minimum number of facilities required to be operated concurrently are the grain
 unloading stations, bin distribution system and loadout stations.  These opera-
 tions, however, do not have to be run simultaneously.

     Grain cleaning is a variable operation which depends on the quality of the
 incoming material and its end use.   Grain drying is somewhat of a seasonal
 operation.  Typically, grain harvested during the late fall and early winter
 months of the year require some drying before storage.  Grain drying, however,
 may also be required at other times of the year, when an elevator receives a
 shipment of material high in moisture content.

     Startup is considered to be when the first shipment of grain is unloaded,
 handled,  cleaned, dried,  or loaded after the affected facility is "ready for
 business."  As stated previously,  the affected  facility is ready for business
 when process equipment have been tested successfully with grain under trial
 conditions at or near design capacity.   As an example, a column dryer could be
 erected and run successfully under actual operating conditions by March 1, on
March 2,  it would be ready for business,  but not begin drying grain until
 October 1.  In this example, the startup date would be October 1.  This scenario
 could apply to all affected facilities of a grain terminal elevator or grain
 storage elevator.  Startup for each operation occurs when grain,  which will be
 exported or processed in a mill for commercial  sale, first enters the facility
 thus initiating the generation of  particulate matter.   Consequently, each af-
 fected facility will more than likely have a different startup date.

     In regards to performance testing of air pollution control devices, the
 attainment of maximum production rates does not depend solely on the performance
 of process equipment but  in part on the incoming grain supply.   It is conceivable
 that  an affected facility of an elevator may not reach its maximum production
rate within 180 days of initial startup.   A well operated elevator,  however,
would not fall into this  category.
                                     127

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                                   REFERENCES
 1.   Environmental Reporter,  Bureau of National Affairs, Inc., 1978, New Source
      Performance Standards Subpart DD, Standards of Performance for Grain
      Elevators.

 2.   Personal Communication with Mr.  John Healy, Grain Elevator and Processing
      Society. Minneapolis, Minnesota, April 23, 1979.

 3.   Personal Communication with Mr.  Robert  Hendricks, Central Soya, Fort Wayne,
      Indiana, April 23,  1979.

 4,   Personal Communication with Mr.  Sims Roy,  U.S.  EPA Standards  Development
      Branch,  Raleigh,  North Carolina,  April  23,  1979.

 5.   Personal Communication with Mr. Leroy Funk, Carter-Day  Company, Minneapolis,
      Minnesota,  April  23,  1979.

 6,   Personal Communication with Mr. Dick Wilbur,  Cargill, Inc., Minneapolis,
      Minnesota,  April  24,  1979.

 7.   Personal Communication with Mr, Stan Gasawskl,  Continential Grain Company,
      St.  Louis,  Missouri,  April  24,  1979.

 8.   Personal Communication with Mr. Hollingsworth,  Aeroglide  Corporation,
      Raleigh, North Carolina, April 24,  1979.

 9.   Personal Communication with Mr. R.  Gillund, Mathews Company,  Crystal Lake,
      Illinois, April 24, 1979.

10,   Personal Communication with Messrs.  James Appold  and Fred Wolf.  The Ander-
      sons, Maumee,  Ohio, April 24,  1979.

11.   Personal Communication with Messrs,  Al  Colby  and  Wes Weber, Archer Daniels.
      Midland  Processing  Company,  Decatur,  Illinois,  and St. Louis, Missouri,
      April 25, 1979.
                                       128

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                    LIME MANUFACTURING PLANTS - SUBPART HH
                               §60.340 - 60.344
Introduction

     The facilities subject to Standards of Performance for Lime Manufacturing
Plants are:  rotary lime kilns and lime hydrators.  A rotary lime kiln is a
unit with an inclined rotating drum which is used to produce a lime product
from limestone by calcination.  A lime hydrator is a unit used to produce a
hydrated lime product.  The pollutant regulated is particulate matter.  Emis-
sion limits established for rotary kilns and hydrators are 0.15 kilogram
per megagram of limestone feed (0.30 Ib/ton) and 0.075 kilogram per megagram
of lime feed (0.15 Ib/ton)  respectively.  In addition, an opacity limitation
of less than 10 percent has been established for rotary lime kiln emissions.
Continuous monitoring of rotary kiln opacity is required, except when using
a wet scrubber emission control device.   Subpart HH does not apply to facili-
ties used in the manufacture of lime at  kraft pulp mills.  Sources constructed,
reconstructed or modified after May 3, 1977, are subject to the regulation.

Process Description

     The sequence of operations in the production of lime are:  1) quarrying
the limestone,  2) crushing and sizing, 3)  conveying, 4) calcination by rotary
kiln, 5)  processing the quicklime (the product of the kiln) by hydration,
6) milling/sizing, and 7) packaging (bulk or bag).  As mentioned above, the
lime manufacturing standard covers only  the calcination and hydration operations.
These two operations are depicted in Figure 27.  "Limestone" means calcitic and
dolomitic limestone, whereas "Lime Product" means the product of the calcination
process including but not limited to calcitic lime,  dolomitic lime, and dead-
burned dolomite.

     Calcination

          A rotary kiln is basically a furnace consisting of a heavy steel shell
lined with refractory brick.  Kilns are  normally fired with one or more of the
following fuels:  natural gas, fuel oil, or pulverized coal or coke.  The kilns
are normally installed at inclines of 3-5° on four to six foundation piers and
revolve on trunnions at 30-50 seconds per revolution.  Rotary kilns will vary
in size ranging from 2 to 5 meters (6.5  to 16 feet)  in diameter to 18 to 183
meters (59 to 600 feet) in length.

          Sized limestone is fed into the elevated end of the kiln and travels
down the length of the kiln towards the  firing end.   The material is heated to a
temperature of  1100°C (2000°F) which chemically breaks down the limestone (CaC03)
to produce quicklime (CaO)  releasing CO?.   Particulate laden gas flows counter-


                                      .129

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                              SIZED
                              STONE
                                                 6AS TO
                                               ATMOSPHERE
             COAL ft AIR
       AIR
                  i
                                i
                               STONE
                      PNCHGNfTEN
       Lime
                 ROTARY
                  KILN
                    GAS
                      STONE
                                GAS
•Q
 FAN
                                                 GAS
PRODUCT
 COOLER
  1
 AIR
                          GAS  TO
                        ATMOSPHERE
LIME
                  SLURRY
                  WATER
     LIME
   STORAGE
             LIME
                   1
                         CONTROL
                          DEVICE
             HYORATOR
                              GAS
WATER
  HYORATED
    LHME
  STORAGE
                                                          WASTE
                                                            TO
                                                          DISPOSAL
Figure 27.  Process flow diagram for lime calcination and hydration.2

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 current  to the limestone, exhausting out the feed end of the kiln.  At the
 lower end of the kiln, the quicklime is discharged to a cooling system.

          Systems to preheat the limestone prior to introduction to the kiln
 are becoming widely used to conserve fuel consumption.  Kilns operated with
 preheaters are shorter in length, requiring 60 to 70 percent less space than
 kilns without them.  Particulate matter emitted from lime rotary kilns are
 usually controlled by cyclones, baghouses, electrostatic precipitators, water
 scrubbers, or gravel bed filters.

     Hydration

          The hydration process is initiated by blending quicklime with water
 in a pug mill premixer.  After mixing, the lime-warer slurry passes to an agi-
 tator-hydrator.   An exothermic chemical reaction takes place in the hydrator
 producing steam,  which is vented to the atmosphere along with any air that enters
 the hydrator through the charging port.  The most common air pollution control
methods used to treat hydrator emissions are water sprays in the hydrator ex-
haust stack or wet scrubbers.

Pre-Startup Operations

     The rotary  kiln is the heart of a lime manufacturing operation; all other
unit operations  are based on the performance of the kiln.   As a result, ancillary
process operations such as crushing, screening, milling, and material and fuel
storage and conveying must be  thoroughly tested under operating conditions prior
to the introduction of limestone into the kiln.  Electrical systems and mechani-
cal equipment are checked out  initially on an individual basis  and then as
integral parts of the process  operation.  Instrumentation and control panels
are also debugged during this  phase.  Likewise, mechanical  equipment are tested
to assure that they are properly installed and  aligned,  and that they are rota-
ting freely and  in the right direction.  During pre-startup, conveyor speeds
are adjusted, feeder rates are monitored and transfer lines are checked for
free passage.  Equipment shakedown of unit operations may occur simultaneously
or in some logical sequence.   The pre-startup shakedown  period  may last from
one to three months.

     In regards  to the rotary  kiln,  once it has been erected, even before it
has been bolted  down,  various  tests  are conducted to check  its  alignment and
rotation.  Upon  passing inspection,  the kiln is then secured to the support
piers and again  checked for alignment and rotation.   A third check is made when
heat is first applied to the kiln.   During this phase, the  kiln may stretch
15 to 20 centimeters (6 to 8 inches) in length  and 0.6 centimeters (0.25 inches)
in diameter.

     One of the most important pre-startup operations is the "seasoning" or
drying out of the kiln.   New refractory brick lining the inner  wall of the kiln
contains residual amounts of water which must be driven  out of  the bricks be-
fore limestone can be fed to the kiln.   The .drying out process  is slow, requir-
ing a gradual warming of the bricks, up to 149  to 204°C  (300 to 400°F), to
prevent cracking  and loosening.  Supplemental gas or oil-fired  burners are

                                     131

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 typically used to season the refractory.  At first the kiln is not  rotated,  then
 as the temperature builds up, operators rotate the kiln so that the refractory
 iB heated evenly.  This process normally takes 3 to 5 days.  Due to equipment
 failures, however, it may take two or three attempts to season the kiln pro-
 perly.  Limestone is not usually Introduced to the kiln during the drying out
 period.

     Water vapor and products of combustion generated during refractory season-
 ing are vented either through the air pollution control equipment or a temporary
 exhaust opening in the ductwork leading to the air pollution control equipment.
 The latter case occurs most often when the control device is a baghouse, con-
 sisting of fabric filters which can be affected by the relatively high moisture
 content of the gas stream.   Once the refractory lining of the kiln has been
 dried out, the kiln can 1)  be shut down while ancillary process equipment are
 being installed or checked out, or 2) can be brought up to its normal operating
 temperature of 1100°C (2000°F) and begin to receive limestone, provided that
 all ancillary equipment have been checked out and readied to commence production.

     Pre-startup of the hydrator and ancillary equipment follows the same
 sequence of shakedowns as the rotary kiln and its associated process operations.
 Similarly, electrical systems and mechanical equipment are Initially tested
 individually and then as a  total unit prior to processing of material.  The only
major difference between pre~startup of the rotary kiln and the hydrator, is
 that the latter does not require seasoning because it is not lined with refrac-
 tory.  The hydrator pre-startup shakedown can last from 2 to 4 weeks.

 Star tup Opera t ions

     Startup for lime manufacturing operations Is generally considered to be the
 first day limestone is fed  into the stone preheater or the rotary kiln, depend-
 ing on the plant configuration.  It is at this time that partieulate matter is
first generated and emitted as an air pollutant from the limestone calcining
operation.  Typically, the  kiln is preheated to 315 to 371°C (600 to 700°F)
before the limestone Is Introduced.  As more material is fed into the kiln, it
Is brought up to its normal operating temperature of 1100°C (2000°F).   Most of
the sources contacted indicated that coal was the principal fuel used to fire
rotary lime kiln furnaces.

     Startup begins an intensive period of equipment shakedown.   Process opera-
 tions must be synchronized,  conveyor and feed systems have to  be adjusted,
Instrumentation has to be rechecked under actual operating conditions, and air
pollution control equipment must be monitored.   One source stated that once
startup has occurred, the kiln could produce at 50 to 70 percent of its rated
capacity within two days, but that It could take two to three  months of debug-
ging and fine tuning before the kiln would be operating close  to design capacity.
Fine tuning would include adjustment of burner positions and primary air feed
rates.  Other delays would  result from the malfunction or failure of auxiliary
 equipment such as conveying systems, material and fuel feeding systems, and
 instrumentation.  Extended  time delays could result if major pieces of process
 .  ilpment had to be reordered.  The sources contacted stated that the 180 day
 p  . iod allowed for equipment shakedown prior to required performance tests pro-
 vided enough time to reach  maximum production rates, unless major process equip-
 ment pieces had to be replaced.

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     Startup for the hydrator is considered to be when quicklime and water first
come into contact in the premixer, usually a pug mill.  Material is fed into
the system at a slow rate at first allowing process equipment to gradually heat
up to a normal operating temperature of 107 to 121°C (225 to 250°F).  After
startup, equipment is monitored, tested and adjustments are made to assure that
all operations are functioning properly.  Sources contacted stated that the
hydrator system, barring mechanical failures, could achieve its design produc-
tion rate within a week of startup.  Air pollution control equipment are also
monitored carefully during the initial days of startup.
                                     133

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                                  REFERENCES
1.   Federal Register 40 CFR Part 60 22506-2251.   Standards of  Performance for
     New Stationary Sources - Lime Manufacturing Plants.   Vol.  42,  No:  85,
     Tuesday, May 3, 1977.

2.   Standards Support and Environmental Impact Statement  Volume  1:   Proposed
     Standards of Performance for Lime Manufacturing Plants.  1977.   U.S.
     Environmental Protection Agency, Office of Air and Water Management.
     Research Triangle Park, North Carolina.  EPA~450/2~77~077a.

3.   Personal Communication with National Lime Association personnel, Washington,
     B.C.,  April 18, 1979.

4.   Personal Communication with Mr. Naumann, Marblehead Lime Company,  Chicago,
     Illinois, April 18, 1979.

5.   Personal Communication with Mr. McCandlish, Flintkote, Monterey  Park,
     California, April 18, 1979.

6.   Personal Communication with Mr. Smithwick, Allie Chalmers, Milwaukee,
     Wisconsin, April 18, 1979.

7.   Personal Communication with Mr. Friend, Vulcan Iron Works, Inc., Wilkes
     Barre, Pennsylvania, April  19, 1979.

8.   Personal Communication with Mr. Schwarzkopf, Kennedy  Vansuan Corporation,
     Danville, Pennsylvania, April 19, 1979.
                                      134         «««. GOVERNMENT MINTING OFFICE: 1980 311-132/23 1-3

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