EPA-450/3-80-030
Source Category Survey
     Detergent Industry
     Emission Standards and Engineering Division
           Contract No. 68-02-3059
     U.S. ENVIRONMENTAL PROTECTION AGENCY
        Office of Air, Noise, and Radiation
     Office of Air Quality Planning and Standards
           Triangle Park, North Carolina 27711

               June 1980

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This report has been reviewed by the Emission Standards and Engineering Division
of the Office of Air Quality Planning and Standards, EPA,  and approved for publication.
Mention of trade names or commercial products is not intended to constitute endorsement
or recommendation for use.  Copies of this report are available through the Library
Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle
Park, N.C. 27711, or from National Technical Information Services, 5285 Port Royal
Road, Springfield, Virginia  22161.
                      Publication No. EPA-450/3-80-030

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                                  PREFACE

     This  revised  Source  Category Survey  Report was  prepared by Midwest
 Research Institute (MRI)  under  EPA Contract No.  68-02-3059,  Task 7.
 The  report was  prepared by  Ms.  Linda  E. Greer for Mr.  James  Eddinger,
 EPA  Lead Engineer.

 Approved for:
 Midwest Research Institute
'LloycKT.  Tayltfr
 Director
 North  Carolina Office

 May  29, 1980
                                    iii

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                            TABLE OF CONTENTS
                                                                      Page

Preface	      11

List of Tables	      1v

List of Figures  	       v

1.0  SUMMARY	       1

2.0  INTRODUCTION  	       3

3.0  CONCLUSIONS AND RECOMMENDATIONS 	       8
     3.1  Conclusions  	       8
     3.2  Recommendations  	       8

4.0  DESCRIPTION OF INDUSTRY 	       9
     4.1  Source Category  	       9
     4.2  Production	      13
     4.3  Process Description  	      13

5.0  AIR EMISSIONS	      18
     5.1  Plant and Process Emissions  	      18
     5.2  Total National Emissions 	      23

6.0  EMISSION CONTROL SYSTEMS  	      24
     6.1  Control Approaches 	      24
     6.2  "Best Systems" of Emission Reduction 	      26

7.0  EMISSION DATA	      27
     7.1  Availability of Data 	      27
     7.2  Sample Collection and Analysis	      27

8.0  STATE AND LOCAL EMISSION REGULATIONS	      28

9.0  REFERENCES	      34
                                    iv

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                             LIST OF TABLES
                                                                      Page
2-1   Components of Powdered Laundry Detergent in the
     United States 	       5
4-1   Industry Statistics ..... 	      10
4-2  Spray-Dry Detergent Manufacturers, 1980 	      11
5-1   Emission Data	      19
5-2  Particulate Emissions From a Typical Spray Dryer  	      22
8-1   Summary of State Air Pollution Regulations  	      29

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                             LIST OF FIGURES
                                                                      Page
4-1  Production of Powdered Detergent and Soap	      14
4-2  Manufacture of Spray-Dried Detergents 	      15
                                    VI

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                              1.0  SUMMARY

     This Source Category Survey Report presents information gathered on
processes, pollutants, and control  equipment associated with the manufacture
of detergent by spray drying.   The source category is a subpart of Standard
Industrial Classification (SIC)  Code 2841.  The production of liquid
detergents, soap, scouring powders, and glycerin and the dry mixing of
powdered detergent were not considered in this report because there was
no evidence of significant emissions from these processes.
     There are 33 plants -n 17 states which currently spray-dry detergent.
Numerous additional small plants produce a small amount (less than 5 percent
of the total U.S. detergent production) of powdered detergent by dry
mixing of raw materials.
     In 1977, there were 1.5xl06 Mg (1.7xl06 tons) of powdered detergent
produced by spray drying or dry mixing.  Average production of spray-dried
detergent was 45,000 Mg/yr (50,000 tons/yr) per plant.  Production of
powdered detergent has  increased slowly in the past 10 to 15 years and is
projected to grow about 1 to 2 percent per year through 1982.  Growth of
the market will be affected by population growth, laundry habits, and
competition from the  liquid detergent market.
     The major steps  in manufacturing spray-dried detergent are: mixing
raw materials to form a detergent  slurry, drying the  slurry by contacting
it with hot air  in a  spray-drying  tower,  cooling product  granules, adding
heat-sensitive materials, and packaging.
     The main pollutant from the production of powdered detergent is
particulate in the form of detergent dust from the exhaust of the spray-
drying tower.  An average of 13 emission  tests show that  typical
controlled  emissions  from the spray dryer are 5  kg/h  (11  Ib/h).  Nationwide
controlled  emissions  were calculated to be  164  kg/h  (363  Ib/h) or

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988 Mg/yr (1,089 tons/yr).   Emissions from raw material and final  product
transport and handling are estimated to be minor.
     Presently, two basic systems are used by the industry to control
emissions from the spray dryer.   One system consists of one or more
cyclonic impingement scrubbers which use a high-solids concentration
detergent slurry.  The other system uses dry cyclones followed by a water
scrubber and electrostatic precipitator.  Both systems allow for product
recovery and are estimated by the industry and equipment vendors to be
approximately 99 percent efficient.
     Typical State Implementation Plan (SIP) particulate regulations for
new plants are expressed by the process weight equation:

          E = 4.1p°-67
where     E = allowable particulate emissions, in Ib/h, and
          p = process weight rate in tons/h.

     The recommended method for sampling particulates from the detergent
industry is EPA Reference Method 5.

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                             2.0  INTRODUCTION

     The authority to promulgate New Source Performance Standards (NSPS)
is derived from Section 111 of the Clean Air Act.   Under the Act, the
Administrator of the U.S.  Environmental Protection Agency is directed to
establish air pollution standards and is accorded the following powers:
     1.  Identify those categories of stationary emission sources that
contribute significantly to air pollution and could be reasonably
anticipated to endanger the public health and welfare;
     2.  Distinguish clc ;es, types, and sizes within categories of new
sources for the purpose of establishing standards; and
     3.  Establish standards of performance for stationary sources which
reflect the degree of emission reduction achievable through application
of the best system of continuous emission reduction, taking into consid-
eration the cost, energy, and environmental impacts associated with such
emission reduction.
     Detergent manufacturing was recently specified on a priority list of
major  source categories for which an NSPS should be developed.1  This
source category survey was performed to determine if an NSPS for the
detergent manufacturing industry is needed and to identify the processes
and pollutants which should be subject to regulation.  Information about
processes, air pollutants, and control equipment was gathered as follows:
     1.  Process and emission data were collected from literature searches,
state  and local air pollution control  agencies, detergent manufacturing
companies, and the National Emission Data System  (NEDS).
     2.  Four detergent manufacturing  plants  were visited to develop  an
understanding of manufacturing processes and  to collect data on  air
pollution control  equipment and  emissions.

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     3.   Representatives of industry, government agencies,  and trade
associations were contacted to gather information on detergent production
and projected industry expansion.
     A detergent is any substance that lowers the surface tension of
water.  Detergents clean by acting as a wetting agent and by holding
soils in suspension.   Scientifically, the term detergent applies to both
soap and synthetic detergents.  However, in common usage (and for the
purposes of this report), soap and detergents are distinguished both by
their composition and by their cleaning performance.  Soap precipitates
as a calcium salt and therefore is not effective in hard water.  Detergent,
a synthetic organic compound, is augmented by water softeners, buffering
agents, and builders and is effective in hard and soft water.2 3 4 5
     The U.S. synthetic detergent industry grew rapidly in volume shortly
after World War II.  Prior to that time, essentially all cleaning and
laundry compositions were based on fatty acid soaps derived from natural
fats and oils such as tallow and coconut oil.6  Modern soap and detergent
formulations were shaped by a series of events which started in the
1930's when the first synthetic surface-acting agent (surfactant), a long
chain alkyl-aryl sulfonate, was introduced.4  Factors that contributed to
increased consumption of synthetic detergent included the development of
economical processes for the manufacture of alkyl-benzene, the discovery
and utilization of phosphate detergent builders, introduction  of automatic
washing machines, steady growth in consumer purchases of clothes, an
increase in washing frequency, and increases in the population.6
     Numerous brands of  laundry detergent are on the market.   A large
number of these have multiple formulas to meet regional phosphorus
legislative  requirements.  There is  no "typical" heavy-duty laundry
detergent formulation; products may  be characterized as high or low
foamers, phosphate or zero-phosphate compositions,  anionic or  nonionic,
built or unbuilt, and any combination thereof.  However, most  detergent
formulations contain at  least the following:  surfactants, builders, foam
regulators,  solubilizers, corrosion  inhibitors, and fillers and diluents.
Table 2-1 gives common components of laundry detergent and their function.

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                               TABLE 2-1.  COMPONENTS OF POWDERED LAUNDRY DETERGENT
                                               IN THE UNITED STATES6
Components
     Commercial examples
 Percent
composition
 by weight
Function
Surfactants
Builders
Foam
regulators
Solubilizers
Antirede-
position
agents
Linear alkylbenzene sulfonates
Alcohol sulfates
Alcohol ethoxylates                8-22
Alcohol ether sulfates
Sodium tripolyphosphate
Tetrapotassium pyrophosphate
Tetrasodium pyrophosphate          20-60
Sodium citrate
Zeolites
Soap
Alkanolamides                      0-5
Fatty amine oxides
Lauryl alcohol
Ethanol                            0-2
Sodium xylene sulfonate
Carboxymethylcellulose             <1
              Lower surface tension;  promote
              emulsification of oil  and grease;
              facilitate penetration  of the fabric
              structure; assist in dispersion of
              particulate matter;  produce foam

              Sequester calcium and magnesium ions;
              prevent redeposition of soil  on
              fabric; maintain alkalinity necessary
              for cleaning; disperse  and suspend
              dirt; increase the efficiency of the
              surfactant

              Boost,  stabilize, and control foam;
              Increase the ability of surfactants to
              go into solution when surfactant
              content is at a high level;
              Prevent removed dirt from returning
              to the fabric

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                                 TABLE 2-1.   COMPONENTS OF POWDERED LAUNDRY DETERGENT
                                                 IN THE UNITED STATES6
                                                      (concluded)
       Components
     Commercial examples
 Percent
composition
 by weight
Function
cr>
       Fluorescent
       whiteners and
       blueing agents

       Corrosion
       inhibitors

       Perfumes and
       colorants
       Fillers and
       diluents
Sodium silicate
Sodium sulfate
Sodium carbonate
Sodium silicate
              Provide a blue-white whiteness to
    <1        counteract the natural tendency
              of some fibers to yellow

    4-10      Protect metal  parts of washing machine
                                   <1        Improve aesthetic appeal
              Provide matrix for free-flowing
    20-40     powder formulations; provide medium
              for compositions;  assist processing
              of the detergent formulation

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     The Standard Industrial Classification (SIC) number 2841 includes
soaps, organic detergent (liquid and powder laundry detergent and
dishwashing liquid), alkaline detergent (automatic dishwashing detergent),
glycerin made from fats, and scouring powders.   Surfactant, the active
ingredient in detergents, is classified in a separate SIC number 2843.7
Technical articles, emission data from state agencies, and discussions
with industry representatives indicate that the manufacturing of spray-
dried powdered detergent is a significant source of particulate emissions
whereas other processes in the industry are not.4 8 9 10  Therefore, this
study will focus on the production of spray dried powdered detergent.

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                  3.0  CONCLUSIONS AND RECOMMENDATIONS

3.1  CONCLUSIONS
     1.   Growth in the liquid and powdered detergent industry has been
slow for the past 10 to 15 years and is projected to be about 1  to
2 percent per year through 1982.  No new spray dryers are expected to be
built within the next 10 years because existing production capacity can
meet the projected demands.  No spray dryer modifications or
reconstructions are expected because spray dryers last indefinitely.
     2.   The primary pollutant from the manufacture of spray-dried detergent
is particulate from the spray-drying operation.  Minor sources of emissions
are raw material and product handling.
     3.   Control technology is available for particulate (detergent dust)
pollution control.  There are no uncontrolled plants in the United States
because the value of recovered detergent dust justifies a high level  of
control.
     4.   Emission data are available for approximately two-thirds of the
plants which manufacture spray-dried detergent.  Test data show that
particulate emissions from plants average 60 percent of emissions allowed
by a typical SIP process weight equation.
     5.   The standard method for evaluating particulate emissions from
spray-drying detergent is EPA Reference Method 5.
3.2  RECOMMENDATIONS
     It is recommended that an NSPS not be developed at this time for the
detergent industry.  A standard would have no  impact because no facilities
are expected to be covered by the standard in  the next 10 years.

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                      4.0  DESCRIPTION OF INDUSTRY

4.1  SOURCE CATEGORY
     The source category considered in this report is the manufacture of
spray-dried detergent.  This category represents approximately 45 percent
of the total products listed under SIC Code 2841.xl  The spray-dried
detergent and soap source category is defined individually by NEDS Source
Classification Code 3-01-009-01.
     Table 4-1 shows that the number of establishments and employees
associated with SIC Code 9841 has been rather stable for the past 20 years.
The total number of establishments has decreased in the past 10 years,
but this decline was probably offset by an increase in establishments
with 20 or more employees.  The total number of employees has increased
from 30,800 in 1963 to 31,900 in 1977.12 13 14 15
     Of the 227 establishments  listed under SIC Code 2841 in 1977, 33
presently spray dry detergents  (Table 4-2).  Facilities are located
in 17 states across the country.  Three major companies, Procter and
Gamble Company, the Colgate-Palmolive Company, and Lever Brothers Company,
supply more than 90 percent of  the retail market demand for detergent and
produce detergent only by spray drying.16  Several other companies,
including Purex Corporation and Witco Chemical Corporation, manufacture
spray-dried detergent to package under their own label or to sell to
distributors.  The remaining companies, although large in number, produce
less than 5 percent of the total laundry detergent used in the United
States.  These small  operations generally produce detergent by dry mixing
ingredients rather than by spray drying.

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                   TABLE 4-1.   INDUSTRY STATISTICS12 13 14 1S

Year
1977
1972
1967
1963
1958
Total No.
of plants
638
642
668
704a
608a
No. of
plants
with >20
employees
227
199
207
172a
163a
Total No. of
employees
(1,000)
31.9
31.5
30.3
30. 8a
29. 6a
No. of
production
employees
(1,000)
20.4
20.4
20.2
20. la
18. 2a
Data for 1963 and earlier are not directly comparable to more recent
data because the industry classification was changed.
                                 10

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            TABLE 4-2.   SPRAY-DRY DETERGENT MANUFACTURERS,  1980
          Company
     Location
The Procter and Gamble Company
The Colgate-Palmolive Company




Lever Brothers



Astor Products

Chemithon

Custom Spray Products, Inc.

The Great Atlantic and Pacific
   Tea Company, Inc.

Los Angeles Soap Company

Luseaux Labs

National Purity Soap and
   Chemical Company

Pacific Soap

PI ex Chemicals
Long Beach, California
Sacramento, California
Augusta, Georgia
Kansas City, Kansas
Alexandria, Louisiana
Baltimore, Maryland
Quincy, Massachusetts
New York, New York
Cincinnati, Ohio
Dallas, Texas

Berkeley, California
Jeffersonville, Indiana
Kansas City, Kansas
Jersey City, New Jersey

Los Angeles, California
Baltimore, Maryland
St. Louis, Missouri

Jacksonville, Florida

Seattle, Washington

Atlanta, Georgia

Brockport, New York


Los Angeles, California

Gardena, California

Minneapolis, Minnesota


San Diego, California

Union  City,  California
                                   11

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            TABLE 4-2.   SPRAY-DRY DETERGENT MANUFACTURERS,  1980
                                (concluded)
          Company
     Location
Purex



Safeway Stores, Inc.

Stepan Chemical

Witco Chemical Corporation
Southgate, California
St.  Louis, Missouri
Bristol, Pennsylvania

Oakland, California

Chicago, Illinois

Chicago, Illinois
Paterson, New Jersey
                                  12

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4.2  PRODUCTION
     Production of powdered detergent has increased slowly in the past 10
to 15 years.   From 1963 to 1977, production increased 37 percent, from
2.4 to 3.3 billion pounds (Figure 4-1).6 12 13 14 1S  Growth in the
detergent market (powders and liquids) is projected to continue at about
1 to 2 percent per year through 1982.6 18
     The powdered detergent market will  be affected by population growth,
changes in consumer laundry habits, and competition from the liquid
laundry detergent market.6 16 17   Rising energy costs will also affect
the spray drying manufacturing process.   Although population growth is
expected to increase the total detergent demand by 500 million pounds by
1985, changes in consumer laundry attitudes and competition from the
liquid detergent market may offset the demand for powders.6 16 17 18  The
liquid detergent market has increased from 3.4 percent (1968) to
16.1 percent (1977) of the home laundry detergent market, and it is
expected to increase to ^8 to 21 percent by 1982.6  Much of the growth in
the total detergent industry is expected to be met by the expanding
liquid market.11
     No new spray driers are expected to be built in the next 10 years to
meet the modest growth forecast for the detergent industry.19 20 21
Industry representatives from two major companies have stated that they
will probably never build another spray dryer.  Excess capacity exists in
the industry to meet projected powdered detergent demand; some plants
spray-dry only two shifts per day, and others have idle spray dryers.19
20 21  The average capacity utilization of spray-dried detergent is
estimated to be near 60 percent.
4.3  PROCESS DESCRIPTION
     Manufacture of spray-dried detergent has three main processing
steps:  slurry preparation, spray drying, and granule handling (Figure 4-2).
4.3.1  Slurry Preparation
     Detergent slurry  is produced by blending liquid surfactant with
other powdered and liquid materials (builders and other additives) in a
crutcher (a closed mixing tank).  The blended slurry is held  in a surge
vessel for continuous  pumping to the spray dryer.  Solids content of the
                                   13

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Million
Pounds
5,000 •
4,000 •
3,000 •
2,000 •
500 -
400 •
300 -
200 -
100 •
.
.
^-"' 'x.x- Household Powdered
/ ^^ Detergent
,
* ^
XNonhousehold Powdered
Detergent
Soap Powder and Flakes
r •
	 1 	 1 	 1 	 1 	 1 	
Million
kg
2,268
-1,814.4
-1,360.8
. 907,2
226.8
• 181
• 136
- 90.7
45.4
      1960  1965  1970  1975  1980
Figure 4-1.   Production of Powdered  Detergent and Soap
                           14

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        RECEIVING
        STORAGE
        TRANSFER
                                            SLURRY PREPARATION
                                                                       SPRAY DRYING
                                                                                  BLENDING
                                                                                    AND
                                                                                  PACKING
     SURFACTANTS:
LAS SLURRY    ALCOHOLS
	ETHOXYLATES
        BUILDERS:
PHOSPHATES   SILICATES
       CARBONATES
      ADDITIVES:
PERFUMES          DYES
   ANTI-CAKING AGENTS
    TO
  CRUTCHER
AND POST-
  ADDITION
  MIXER
                                                                                                      FINISHED
                                                                                                      DETERGENTS
                                                                                                         TO
                                                                                                      WAREHOUSE
                              Fiqure  4-2.   Manufacture of spray-dried detergents.

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slurry varies from 50 to 70 percent by weight at most plants.   Dust
emissions are generated by handling and conveying of the powders,  but
these emissions are contained in the building or controlled with fabric
filters and are not considered significant.8 10
4.3.2  Spray Drying
     The spray-drying operation is the major source of particulate emissions
from detergent manufacturing.4 8 9 10 It is also a minor source of                    [
hydrocarbons when the product being sprayed contains organic materials
with low vapor pressures.
     Slurry feed to the tower is atomized by spraying at high pressure
through nozzles.  Typical towers are cylindrical with cone-shaped bottoms
and range in size from 3.7 to 7.4 m (12 to 24 ft) in diameter and 30 to
38 m (100 to 125 ft) in height.  Typical feed rates vary from 5,400 to
6,800 kg/h (12,000 to 15,000 Ib/h).  Air is supplied to the tower from
direct-heated furnaces fired by either natural gas or fuel oil.  Most
towers designed for detergent production are countercurrent, with slurry
introduced at the top and heated air introduced at the bottom.  A few
towers are concurrent and have both hot air and slurry introduced at the
top.
     Tower operating parameters vary widely from manufacturer to
manufacturer and product to product.  Heated air supplied to the tower
varies from 315°C to 400°C (600°F to 750°F).  Moisture content of the
final product varies from 10 to 17 percent.  Exit gas temperatures range
from 65°C to 120°C (150°F to 250°F).
     In countercurrent towers, the low air velocities and large particle
size allow most of the dried granules to fall to the bottom of the tower.
The granules are discharged through a regulated opening (star valve)
while still hot.  In concurrent towers, the air is vented just above the
bottom of the tower through a baffle, changing the direction of the air
and causing the dried granules to fall to the cone bottom.  The loss of               ;
detergent fines is higher from the concurrent towers than from the                    ;
countercurrent towers because the particles produced in concurrent towers
are smaller.10
                                  16

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                4.3.3  Granule Handling
                     Granules are mechanically or air conveyed from the tower to a mixer
                to incorporate additional  dry or liquid ingredients.   Air conveying cools
                the granules during transport.   At the end of the conveyor,  centrifugal
                separators remove granules from the air.   The cooled granules are screened
i                to remove oversized or undersized particles,  blended with final  heat-
|                sensitive additives, and conveyed to packaging and storage.   The conveying,
                mixing, and packaging of granules cause in-plant dust emissions  which  are
                generally controlled by baghouses.8 10
                                                  17
                A

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                           5.0  AIR EMISSIONS

5.1  PLANT AND PROCESS EMISSIONS
     Emission test data for specific plants were requested from state and
local control agencies and individual plants.  Additional emission data
were obtained from a previous EPA testing program, EPA's National Emissions
Data System (NEDS), and other literature sources.4 8 10   Table 5-1
presents a compilation of testing results and emission estimates obtained
in this survey.  The 22 plants for which data were obtained have a
production and emission range which is characteristic of the 33 plants
which spray-dry detergent in the United States.  Emissions range from 0.6
to 20 kg/h (1.3 to 44 Ib/h).  Testing results show that the average
emission rate is 5 kg/h (11 Ib/h), which is 30 Mg/yr (33 tons/yr), assuming
a 3-shift day and 5-day workweek, 50 weeks per year.
     Table 5-2 shows the average emission rate (calculated by averaging
emission test data) and SlP-controlled emission rate for a typical
detergent plant.  The typical SlP-controlled estimate was obtained by
dividing the total 1977 U.S. production of powdered laundry detergent by
the  number of plants in operation.  This production rate (in tons of
detergent per year) was converted to an average plant detergent  slurry
feed rate (process weight rate).  The process weight rate was used in a
typical process weight equation:

                E = 4.1p°-67
     where      E = allowable particulate emissions, in  Ib/h, and
                p = process weight rate, in tons detergent slurry/h.

This typical process weight equation  is used in 10  of  the 19 states which
have detergent  plants  in the U.S.

                                  18

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TABLE 5-1.  EMISSION DATA

Plant
A


B


C
D


E

F

G




H


Date
of data
1972
7/73

4/73


5/72
7/72


6/72
1973
4/73

1973




2/74


Method
EPA 5
EPA 5

EPA 5


EPA 5
EPA 5


EPA 5
EPA 5
EPA 5

EPA 5




EPA 5


N
Control
device
cyclonic
Impingement
scrubber
cyclonic
Impingement
scrubber
baghouse
cyclone
Impingement
scrubber
cyclone,
scrubber-ESP
cyclone,
scrubber-ESP
cyclonic
Impingement
scrubber,
fiberglass
filter
cyclonic
impingement
scrubber
Emission
range
Ib/h
0.7-2.4
7.5-8.65

6.35-16.81


44.11-45.19
3.15-4.65


17.3-23.11
— —
6.4-9.03

8.6-13.6




1.6-5.3


Emission
average
Ib/h
1.66
8.02

9.35


44.11
3.78


21.01
25
8.1

10.6




3.2


Emission
average
kg/h
0.8
3.6

4.2


20.0
1.7


9.5
11.3
3.7

4.8




1.4


No. of
tests
3
3

3


2
3


3
—
3

3




3



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                                             TABLE 5-1.  EMISSION DATA

                                                    (Continued)
ro
o

Date
Plant of data
I 1975


J 1977

K 1978
L 1978
M

N

0

P

Q


R

Method
EPA 5 Mod.


EPA 5 Mod.

EPA 5 Mod.
EPA 5 Mod.
EPA 5 Mod.

Estimate*

Estimate

Estimate

Estimate


Estimate

Control
device
cyclonic
impingement
scrubber
cyclone,
scrubber-ESP
NA
cyclone
cyclonic
scrubber
cyclone,
scrubber-ESP
cyclone,
scrubber-ESP
cyclone,
scrubber, -ESP
cyclonic
impingement
scrubber
cyclone,
wet scrubber
Emission Emission
range average
Ib/h Ib/h
5.2-9.5 6.9


14

4
1.4
4.8

6.6b

15b

10.7b

3.7b


25 tons/yr- 17.8b
82 tons/yr
Emission
average
kg/h
3.1


6.4

1.8
0.6
2.2

3.0b

6.8b

4.8b

1.7b


8.1b

No. of
tests
4


M

-
-
_

0

0

0

0


0


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                                       TABLE 5-1.  EMISSION DATA
                                              (Continued)


Date
Plant of data
S
T
U
V

Method
Estimate
Estimate
Estimate
Estimate
Emission
Control range
device Ib/h
cyclone
cyclone,
scrubber-ESP
cyclone
cyclone
Emission
average
Ib/h
1.3b
6b
9.6
1.6
Emission
average
kg/h
0.6b
2.7b
4.4
0.7

No. of
tests
0
0
0
0
Esimates were made by state agencies based on efficiency of the air
pollution control devices installed at. the plant.  It is not known if
these estimates are accurate.
Estimate assumes plants operate 6,000 h/yr.

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            TABLE 5-2.  PARTICULATE EMISSIONS
               FROM A TYPICAL SPRAY DRYER
Typical spray dryer emissions:

     Uncontrolled                   500 kg/h (1,100 Ib/h)

     Controlled for product          50 kg/h (110 Ib/h)
       recovery only

     Average controlled:3             5 kg/h (11 Ib/h)

     Typical SIP controlled:5         9 kg/h (19 Ib/h)
 Average plant emissions were estimated by averaging
.available test results.
 Typical plant emissions were estimated assuming a
 production rate of 45,300 Mg/yr (50,000 tons/yr),
 a process weight rate of 57,000 Mg/yr
 (62,500 tons/yr), and an operating rate of
 6,000 hours per year.
                         22

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     Data obtained from state agencies and detergent companies indicate
that the detergent plants commonly emit less participate than is allowed
by SIP's.  A comparison of the average emission rate and the SIP-
controlled emission rate shows that plants are emitting 60 percent of the
particulate allowed by the typical state regulations.
     No uncontrolled detergent plants exist in the United States because
it is not profitable for the plants to lose detergent powder to the
atmosphere.  Plants which use collection devices only for product recovery
remove 85-95 percent of particulate emissions.  These plants are estimated
to emit 50 kg/h (110 Ib/h).
5.2  TOTAL NATIONAL EMISSIONS
     Baseline nationwide particulate emissions are estimated to be
988 Mg/yr (1,089 tons/yr).  The nationwide emission rate was estimated by
multiplying the average plant emission rate by the number of plants which
spray-dry detergent in 1980.
                                  23

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                      6.0  EMISSION CONTROL SYSTEMS

6.1  CONTROL APPROACHES
     There are three sources of particulate emissions in the manufacturing
of spray-dried detergent:  unloading,  conveying, and mixing dry materials;
spray-drying detergent slurry; and conveying and packaging the final
product.   The major source of emissions,  the spray drying of detergent
slurry, generally is controlled in two stages.   A primary control  device
(dry cyclone or cyclonic impingement scrubber)  is used largely for product
recovery, and a secondary device [mist eliminator or scrubber-electrostatic
precipitator (ESP) unit] is used for particulate air pollution control.
The other emission sources are controlled by fabric filters which serve
both for air pollution control and product recovery.
6.1.1  Emission Control for the Spray Dryer
     6.1.1.1  Primary Collection Equipment.  Two types of primary collection
equipment are used by the soap and detergent industry to control emissions
from spray drying—the dry cyclone and the cyclonic impingement scrubber.
The dry cyclone is used in parallel or in series to collect particulate
(detergent dust) and recycle the dry product back to the crutcher.  The
cyclonic impingement scrubber is used in parallel and collects the
particulate in a scrubbing slurry which is recycled back to the crutcher.
     The cyclone separates particulate matter from the effluent gas by
changing the direction and velocity of the inlet stream.  Centrifugal
force moves the particulates to the outside wall for collection.  The
cyclone's collection efficiency is dependent on the inlet gas velocity
and the particle size  in the gas stream.
     Because the particulates in the gas stream from the spray dryer are
large  (approximately 50  percent are greater than 40 microns), the cyclone
efficiency  is high.8 22  Typically, a single cyclone is 90 percent efficient
                                  24

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with a pressure drop of 1,000 to 1,250 Pa (4 to 5 inches of water).10 26
Two cyclone collectors in series operate at 3,000 Pa (12 inches of water)
and are reported to have collection efficiencies of 99 percent.10
     In cyclonic impingement scrubbers, the air stream enters tangentially
near the bottom and flows upward in a spiral.   A countercurrent flow of
high-solids-concentration slurry is used to contact the dust particles
and absorb them.  The scrubbing slurry drains out of the bottom of the
unit, and the clean air leaves through the top.4  The slurry is recycled
through the scrubber at a constant solids concentration by continuously
returning part of the slurry to the process and diluting the remaining
slurry with water.
     The efficiency of the cyclonic impingement scrubber depends on a
proper balance between the air and the scrubbing slurry flow rates.23
Pressure drop varies from approximately 500 to 2,000 Pa (2 to 8 inches of
water), and the slurry flow rates vary from 0.5 to 1.3 liters of slurry
per cubic meter of air (4 to 10 gpm slurry per 1,000 cfm air).10  The
equipment manufacturer states that this type of scrubber has an efficiency
of at least 99 percent for particles greater than 3 microns.24 2S
     6.1.1.2  Secondary Collection Equipment.   Secondary collection
equipment is used at well-controlled detergent plants to capture the
fine particulates that have escaped from the primary devices.  Plants
with cyclonic impingement scrubbers often use mist eliminators as secondary
collectors.  Dry cyclones may be followed by fabric filters or, more
commonly, by scrubber-electrostatic precipitator units.  Generally, it is
not economical to recover the portion of the product captured by secondary
devices; collected material is disposed as solid or liquid waste.
     A typical scrubber-ESP unit is enclosed in a cyclindrical vessel
about 4.3 m (14 ft) in diameter and about 12.2 m (40 ft) high.  A tubular
type ESP is located in the upper part of the vessel.  The scrubbing
section, in the lower part of the vessel, contains a 23-cm (9-inch) layer
of pall ring packing with spray nozzles underneath.  Each scrubber uses
fresh water at about 4.1xlO-3 to 5.7xlO-3 m3/s (65 to 90 gpm).  The
collected material is washed from the ESP tubes with water every 3 to
5 days while the unit is shut down.26  The scrubber-ESP unit collects
                                  25

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small particle sizes, has low pressure and temperature drops, operates
continuously, has a low maintenance costs, and requires little power to
operate.10  It is approximately 50 percent efficient.26
     Although fabric filters have been used by some companies to control
the spray dryer, few are presently used for this purpose.   Problems with
bag blinding and bag burning made fabric filters undesirable control
devices for the spray dryer.
6.1.2  Emission Control for Raw Material and Final Product Handling
     Fabric filters are used extensively for the control of dust emissions
from raw material unloading, conveying, and mixing, and from product
conveying and packaging.  Filter material such as polyester and Dacron is
used to control emissions from raw material handling because it is
resistant to alkaline powders.  Fabric filters used for final product
emission control may be made of cotton sateen.
     The fabric filters used in the industry vary in inlet capacity from
9.4 m3/s (20,000 acfm) for small units to 37.8 mVs (80,000 acfm) for
large units.10  Air-to-cloth ratios range from 2.5 to 1 to 6 to 1.10 27
Some manufacturers report efficiencies of fabric filters exceed
99.8 percent.27
6.2  "BEST SYSTEMS" OF EMISSION REDUCTION
     Two major control systems are used by the soap and detergent industry.
The control system most widely used consists of a cyclonic impingement
scrubber occasionally followed by a mist eliminator or  similar type of
secondary aftercollector.  A second system consists of  cyclones in parallel,
followed by a  scrubber-ESP  unit.  Both systems can achieve effective
product recovery and air pollution control.  Design collection efficiencies
for both systems are approximately 99 percent according to the detergent
companies and  control equipment vendors.
                                   26

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                           7.0  EMISSION DATA

7.1  AVAILABILITY OF DATA
     Emission data were obtained through telephone and letter contacts to
state and local control agencies, visits and letters to individual
companies, and the NEDS.  In addition, particulate emission rates and
particle size distribution were obtained from a previous EPA testing
program of six detergent plants.  Most of the emission data that was
available was only for the spray-drying operation.  Little data was found
on other steps in the manufacturing of powdered detergent and on the
manufacture of other detergent products (such as liquid detergent and bar
soap).  A small amount of data on N02, S04, P04, C04, and Si02 emissions
from a spray dryer were provided by an EPA test at one plant.
     Data on uncontrolled plants is not available in the United States
because all detergent spray dryers are controlled to prevent loss of
product.
7.2  SAMPLE COLLECTION AND ANALYSIS
     Particulate emissions from detergent manufacturing are measured
using EPA Reference Method 5.  EPA Reference Method 9 is available for
determination of opacity.  Both EPA Reference Methods 5 and 9 are described
in 40 CFR 60, Appendix A.28
                                  27

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                8.0  STATE AND LOCAL EMISSION REGULATIONS

     The following paragraphs provide information on pertinent state and
local regulations.   These data were compiled from telephone contacts and
letter requests to specific pollution control agencies and from the
Environment Reporter.29
     Spray dry detergent manufacturing plants operate in 17 states.   All
17 states have emission regulations for particulate, and all except two
regulate opacity (Table 8-1).  None of the states has developed emission
standards specific to new or existing detergent manufacturing plants;
most state regulations categorize this source as a "manufacturing"
process.
     Seven of the seventeen states listed in Table 8-1 use the following
process weight rate equations to establish allowable particulate emissions:
          E = 4.10 p°-67      p^30 tons/h
          E = 55.0 p0-11-^   p>30 tons/h
    where E = allowable particulate emission rate, in Ib/h, and
          p = process weight rate, in tons slurry/h.
     The remaining ten states have different process weight rate tables
and equations.  The California South Coast Air Quality Management District
(SCAQMD) uses a more restrictive table than the other states.  An average-
sized plant (with a process weight rate of 10 tons/h) which would be
allowed to emit 8.6 kg/h  (19 Ib/h) of particulate using the above equations
would be limited to emitting 5.4 kg/h (12 Ib/h) particulate in the SCAQMD.
     Most states which have  detergent manufacturing plants  limit opacity
to 20 percent with exceptions which permit higher levels  for a small
percentage of time in an  hour or day.
     All state and local  agencies  contacted  indicated that  their detergent
plants were operating within applicable particulate regulations.  To meet
                                  28

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                                  TABLE 8-1.   SUMMARY OF STATE AIR POLLUTION REGULATIONS
        State
Particulate
Opacity
Air pollution regulation reference
ro
10
        California

          Bay Area     Equation Set T
          South Coast  Process weight
                       rate table 405,
                       Type A
                      §20, exception


                      520, exception
                 Bay Area Air Control District, Reg.  IV.
                 September 1977.

                 Rules and Regulations South Coast Air Quality
                 Management District, Reg.  IV.  September 1977.
Florida
Georgia
Illinois
Indiana
Kansas
Louisiana
Maryland
Equation set 2
Equation set 1°
Equation set 3
Equation set 1
Equation set 1
Equation set 1
SO. 03 gr/dscf
S20, exception
^20, exception
530, exception
540, exception
—
_ — _
520, exception
Rules of the Florida Department of Environment
Regulation. Chapter 17-2.13. September 1979.
Georgia Air Quality Control Rules. Chapter 391-3-1.
November 1975.
Illinois Stationary Sources Standard.
Rule 201, 202, 1977. May 1979.
Indiana Air Pollution Control Regulations. APC-3.
May 1979.
Kansas Air Pollution Control Regulations.
Section 28. January 1974.
Louisiana Air Pollution Control Regulations.
19.4 and 19.5. February 1978.
Maryland State Department of Health and Mental
                                                              Hygiene Regulations Governing the Control of Air
                                                              Pollution.   Area HI.   April 1979.

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                          TABLE 8-1.  SUMMARY OF STATE AIR POLLUTION REGULATIONS
                                               (continued)

State
Massachusetts
Minnesota
Missouri
New Jersey
New York
Ohio
Pennsylvania
Parti cul ate
Table 6
Equation set 2
Equation set 1
5.02 g/dscf or
99% reduction
Equation set 4e
Equation set 1
5.02 g/dscf or f
or Equation 5
Opacity
520,
520,
520,
520,
520,
520,
520,
exception
exception
exception
exception
exception
exception
exception
Air pollution regulation reference
Massachusetts Air Pollution Control Regulations.
Section 7.09(u). October 1978.
Minnesota Air Pollution Control Rules, Regulations,
and Air Quality Standards. APC-5. June 1976.
Missouri Air Pollution Control Regulation.
10 CSR 10-5. December 1979.
New Jersey Regulations on Air Pollution from
Manufacturing Processes. Subchapter 6. May 1977.
New York Regulations on Processes and Exhaust.
Title 6, Chapter III, Part 212. June 1973.
Ohio Particulate Matter Standards. September 1978.
Pennsylvania Standards For Contaminants.
Section 123. July 1978.
Texas
Equation set
520, exception   Texas Regulation 1:   Control of Air Pollution From
                 Visible Emissions and Particulate Matter.
                 Section 131.   May 1979.
Washington     50.1 gr/dscf
                      520, exception   Washington General  Air Pollution Regulations.
                                       WAS 173-400-040.   December 1976.

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                          TABLE 8-1.  SUMMARY OF STATE AIR POLLUTION REGULATIONS
                                               (continued)
Equations
  E = allowable emission rate in Ibs/h
  p = process weight rate in tons/h

aEquation set 1:
  (a)  E = 4.1p°-67      p^30 tons/h
  (b)  E = SSp0-11-^    p>30 tons/h

 Equation set 2:
  (a)  E = 3.59p°-62     pg30 tons/h
  (b)  E = 17.31p°-16    p>30 tons/h

cEquation 1 (a) above is used for all existing equipment.

 Equation set 3:
  (a)  E = 2.54p°-534    pS450 tons/h
  (b)  E = 24.8p°-16     p>450 tons/h

New sources are subject to the restrictions of this equation.   Existing sources are subject to the
restrictions of Equation Set 1.

eEquation set 4:
  (a)  E = 0.024p°-665   pS50 tons/h
  (b)  E = 39p°-b82-50   p>50 tons/h

 Equation set 5:
  (a)  A = 0.76E0-42  where
     A = allowable emissions in Ib/h
     E = FxW
         F = process factor in Ib/unit = 30 Ib/ton for detergent drying, and
         W = production or charging rate in units/h.

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                                TABLE 8-1.   SUMMARY OF STATE AIR POLLUTION REGULATIONS
                                                      (concluded)
       Equation set 6:
            E = 0.048q°-62
            q = stack effluent flow rate in acfm.
                If the source has an effective stack height less than the standard effective stack height,
                the allowable emission level must be reduced.
OJ
ro

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increasingly stringent air pollution control laws in some states, the
industry has added control equipment for particulate and opacity reduction
and has increased maintenance checks on existing control equipment.
Personnel from a few states mentioned occasional complaints about detergent
"fallout," but stated that this problem was generally caused by equipment
failure or process upset conditions at the plant.  There are occasional
complaints in some areas concerning odors from detergent plants, but
these problems have usually been corrected by changes in the process or
by further addition of control equipment.
                                  33

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9.0  REFERENCES

 1.  U.S. Environmental Protection Agency.  Code of Federal Regulations.
     Title 40, Chapter I, Subchapter C, Part 60.16.  Washington, D.C.
     Office of the Federal Register.  August 21, 1979.

 2.  Standard and Poor.  Industrial Surveys: Chemical Basic Analysis.
     August 30, 1979.  p. C25-C26.

 3.  Train, R. E., J. L. Agee, A. Cywin, and R. T. Gregg.  Development
     Document for Effluent Limitations Guidelines and New Source
     Perfonnance Standards:  Soap and Detergent Manufacturing Point
     Source Category.  U.S. Environmental Protection Agency.  Washington,
     D.C. Publication No. EPA-440/1-74-018a.  April 1974.  202 p.

 4.  Boys, P. A.  Air Pollution Control Technology and Costs in Seven
     Selected Areas.  U.S. Environmental Protection Agency, Research
     Triangle Park, N.C.  Publication No. EPA-450/3-73-010.  December
     1973.  708 p.

 5.  Shreve, R. N. and J. A. Brink, Jr.  Chemical Process Industries.
     New York, McGraw-Hill Book Company, 1977.  p. 482-506.

 6.  Stanford Research Institute.  Chemical Economics Handbook.
     Menlo Park, CA. September 1978.

 7.  Standard Industrial Classification Manual.  Bureau of the Census.
     Washington, D.C. 1972.  p. 583.8001 A-583.8001 M.

 8.  Phelps, A. H., Jr.  Air Pollution Aspects of Soap and Detergent
     Manufacture.  Journal of the Air Pollution Control Association.
     17:505-507.  August 1967.

 9.  Environmental Engineering, Inc, PEDCo  Environmental Specialists,
     Inc. Draft Background Information for  Establishments of National
     Standards of Performance for New Sources.  Contract No. CPA 70-142.
     Task Order No. 8 for the Environmental Protection Agency.
     Gainsville, Florida.  July 1971.  46 p.

10.  U.S. Environmental  Protection Agency.  Air Pollution  Engineering
     Manual.  AP-40.  Research Triangle Park,  N.C.  May 1973.   p.  737-765.

11.  Brenner, T. E.  Soap and Detergents -  North American  Trends.  Soap/
     Cosmetics/Chemical  Specialities,  p. 44-52, 80-83.  February  1978.

12.  U.S. Department of  Commerce:  Bureau of the Census.   Census of
     Manufacturers.  Washington,  D.C. 1963.  p. 28D-1  to 28D-18.

13.  U.S. Department of  Commerce:  Bureau of the Census.   Census of
     Manufacturers.  Washington,  D.C.  1967, p.  28D-1  to 280-14.
                                   34

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14.  U.S. Department of Commerce:   Bureau of the Census.   Census of
     Manufacturers.   Washington, D.C. 1972, p. 28D-1  to 280-24.

15.  U.S. Department of Commerce:   Bureau of the Census.   Census of
     Manufacturers.   Washington, D.C. 1977, p. 1-9.

16.  Detergent Sales Expected to Reach $6.1 Billion by 1982.   Soap/
     Cosmetics/Chemical Specialities,  p. 40.  April  1978.

17.  Slow Growth Predicted for Household Cleaning Products.  Soap/
     Cosmetics/Chemical Specialties,  p. 48.  November 1979.

18.  Laundry Detergents to Lead Growth in Household Cleanser Market.
     Soap/Cosmetics/Chemical Specialities,  p. 47-49. August 1979.

19.  Memo and attachments from Greer, L. E., Midwest Research Institute
     to Eddinger, 0., EPA/ISB.  April 1, 1980.  Report of visit to the
     Colgate-Palmolive Company (Jersey City, New Jersey plant) on
     March 20, 1980.

20.  Memo and attachments from Greer, L. E., Midwest Research Institute
     to Eddinger, J., EPA/ISB.  April 1, 1980.  Report of visit to Witco
     Chemical Corporation (Paterson, New Jersey plant) on March 21, 1980.

21.  Memo and attachments from Greer, L. E., Midwest Research Institute
     to Eddinger, J., EPA/ISB.  April 25, 1980.  Report of visit to Procter
     and Gamble Company (Augusta, Georgia plant) on April 22, 1980.

22.  Envirotech, Buell Emission Control Division.  Buell Mechanical
     Collectors.  Form S202/0579.  Lebanon, Pennsylvania.  1974.  8 p.

23.  The Ducon Company, Inc.  MuHivane Gas Scrubber.  Bulletin
     Number W-1273.  Mineola, New York.  1973.  4 p.

24.  Telecon.  Sinclair, J., The Ducon Company, with Antel, D., Midwest
     Research Institute.  April 17, 1980.  The performance of Ducon
     scrubbers in the detergent industry.

25.  The Ducon Company, Inc.  Product Recovery and Air Pollution Control
     and Penumatic Conveying.  Bulletin No. A-9171a.  Mineola, New York.
     Undated.  4 p.

26.  Bell, D.  Procter and Gamble Testing Report, Augusta, Georgia.  U.S.
     Environmental Protection Agency.  Contract Number 68-02-0233.
     Research Triangle Park, N.C.  June 1972.  93 p.

27.  Telecon.  Kury, W., W. W. Sly Mfg. Co., with Antel, D., Midwest
     Research Institute.  March 18, 1980.  The use of fabric filters by
     the detergent industry.
                                  35

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28.  U.S. Environmental Protection Agency.  Code of Federal Regulations.
     Title 40, Chapter I, Part 60, Appendix A.  Washington, D.C.  Office
     of the Federal Register.  July 1, 1979.

29.  Stewart, J. D.  Environment Reporter.  Bureau of National Affairs,
     Inc.  Washington, D.C.  1979.
                                   36

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before compietingl
T REPORT NO.

  EPA/3-80-030
47TITLE AND SUBTITLE
                              2.
                                                            3. RECIPIENT'S ACCESSION NO.
                                5. REPORT DATE
                                   June 1980
  Source Category  Survey:

7. AUTHOR(S)
Detergent  Industry
                                                            6. PERFORMING ORGANIZATION CODE
                                8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS

  Midwest Research Institute
  4505 Creedmoor  Road
  Raleigh, North  Carolina  27612
                                                             10. PROGRAM ELEMENT NO.
                                11. CONTRACT/GRANT NO.


                                   68-02-3059
12. SPONSORING AGENCY NAME AND ADDRESS
  ESED, OAQPS
  U.S. Environmental Protection  Agency
  MD-13
  Research Triangle Park. North  Carolina  27711
                                                             13. TYPE OF REPORT AND PERIOD COVERED
                                                               Final
                                14. SPONSORING AGENCY CODE

                                   EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
       Background information  is presented on  the detergent manufacturing industry
  for the  purpose of assessing the need for new source performance standards.  The
  report contains information  on industry statistics and processes, air emissions,
  and emission control equipment associated  with spray-dried  powdered detergent.
  The spray dryer used to  produce powdered detergent is the only major source of
  particulate emissions.   No new spray dryers  are expected to be constructed,
  reconstructed, or modified within the next 5-10 years.  The report recommends
  that standards of performance should not be  developed at this time.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b. IDENTIFIERS/OPEN ENDED TERMS  C.  COSATI I icId/Group
    Detergents
    Surfactants
    Spray dryers
    Air  pollution
    Pollution control
    Standards of performance
                     Air Pollution Control
                                                    13-B
18. DISTRIBUTION STATEMENT


  Unlimited
                   19 SFC'.'F'T' CLASS  TVir.s Rep:•»••..
                   	Unclassif|ed
                   2C S* ~:;r>:~ •' Cl.AJS 'T-'is punt i
                        Unclassified
 21. NO. OF PAGES

!	36	
f~22. PRICE
EPA Form 2220-1 (Rev. 4-77)    PREVIOUS EDITION is OBSOLETE

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