Document N5vZd7LyBXM2DyrQZan8r83Q

/ '/ ' V1* i Statement of G A P Prepared for Agency of Environmental Conservation1 Informal Hearing . Septeaber 23, 1971 On August 27, 1971, a Notice of Violation was issued by the Vermont Agency of Environmental Conservation, Division of Environmental Protection, relating to the opacity of . the discharges from the rock drying operations at our plant located near $rde Park, Vermont. On Septeaber 1U, 1971, 01? Corporation requested a hearing on the matter, for which we are present tedsy. Firet, we voold like it to be known that OAF is actively concerned with all phases of anvironiaantel lsprovenents. Some years ago, a Corporate Environmental Engineering Department ires established to work with the plants and regulatory agencies in achieving qoapliance with pollution control regulations. At oar $nde Park plant, the management and engineering staffs of the plant, themselves, have devoted a great deal of effort to these problems, and we will appreciate an ^opportunity now to review those past efforts end to describe present end fa tore plans. The dost sources which are of immediate concern include the two rock dryers, and a ember of dry material transfer points, between conveyors and beteaan conveyors and Stock or waste piles* The problem of the dryer emissions was first investigated in 1967. During that year, and the following, a study was made to determine what < i ! .1 I i; ' i i- I ! GAF 11173 .rf.'!' AJT '.'JSv1! 'rJ u-,,-Wp"J V .rJi 2 .4 control methods might be in use by others in the industry. Visit* worn made to the Canadian facilities of Johns-ifenville Corporation and the rVllp Carey Company and it was lcimod that Johns-Itimrille had developed a high-efficiency cyclone collector that was quite effective in operation. The diagram for this system were given to our Hyde Park plant by Johns-ffenville,but son* Modifications were needed to suit our operation. Engineering design began in 1969, and the plans called for keeping an existing primary scalping cyclone in use, since the recovored material could be returned to process. Also, in anticipation of additional State air pollution control regulation? it was proposed to follow the secondary, high-efficiency cyclones with wet scrubbers. * This proposed control system was discussed with the Vernent Division of Industrial i^giene late in 1969, and, since State control regulations hac not yet been forsolated, there were some reservations that the scrubber would provide the necessary final degree of control. It was decided that the neat practical vay of achieving an immediate reduction in emissions would be to proceed with the cyclone installations with the intention of installing follow-up collection devices after emission lindts became known. 1 Accordingly,, design was completed, the cost was estimated, and the funds were authorized in June, 1970. The equipment uas built by Duson, Inc. and the instillation was completed by the end of 1970, at a cost of over $50,000. (Ihieon guaranteed an 87? efficiency for the cyclones, at operatic j i i` 1I :i 1 GAF 11174 Ttt" V V' U.^flgT irMM iiWi^^fiiaii'irfi iiif~i ^f******^^ Itmr ^*** 3. 4 corriitiona of 22,000 A.C.P.it. and 11" H2O prnssurs drop. The plant has verifiod tho volum* and pressure drop. Various alternative methods of additional control are now under study. Informtion on ventnrl wet scrubbers has been obtained from Pulverizing Machinery Co. and Ducon, Inc. Data on bag collectors has boen supplied by Research-Cottrail and Pulverising ItschineryThe Whealabrator Cospaqy will also be requested to submit a proposal. A final choice of equipment will depend upon the potential hazard of creating a water pollution problem, the experience of other manufacturers in utilizing the equipment in similar service, and the ultimate emission limits that out be mat. With regard to the dust generated by the transfer of dry failing* from one conveyor to another, and from a conveyor to the waste pile, a number of options are being considered. A trial application of cater to tho dry fines was mads earlier this year. It demonstrated considerable effectiveness in suppressing the dust, but the transfer chutes quickly become plugged. P-edesign of the transfer chutes might eliminate that difficulty, but it remains to be determined if water could continue to be applied during the winter season. As an alternative, snail bag collectors could bs installed at each transfer point. Reeearch-Cottrell and Pulverizing fhchlrery have been asked to submit proposals. How power is to be brought to the various locations, and how the collector is to discharge the collected material, are questions that remain to be answered. GAF 11175 Osevuy of approaching the prnblen is to eliminate an nary transfepoir.ts as possible, and the plant is ntudying the reusability of U3ing lor.-or individual bolts for that i*irp03o. ) Ua believe that CIAF has shown a positive interest in improving ' - dust conditions at its fty'de Park plant. Ibeh was done even before air pollution control became of national concern. :bre needs to be done, of coarse, and oar future coarse of action will be guided by regulation and engineering considerations. Of prime importance are the regulations that will be put into effect by the State of 7eraont and the Federal Oovsrcraent. The proposed national rdsaion standards for tha asbestos lndnstry are very stringent and, if adopted, *ny require mare elaborate control methods than those that are now under investigation. Sicca a decision is expected in the near future, it would be preferable to defer a final choice of control system until it is known. In the meantime, however, engineering evaluations will be rode of the equipment currently being considered. This will involve further visits to- ether asbestos Bills that have hart sons experience with particular types of equipnent. Also, we believe it would be benefit to install one of the snail bag collectors at a transfer paint, for pilot purposes and to develop installation and design criteria for the other locations. GAF 11176 5. At this tiae, it is difficult to predict the daratioa of the eagiaeeriag phase, especially without knowing the specific eaissioa limits that we will have to seat. If you wish aa to proceed oa the basis of the Veraoat regulations, we estiaate that a progrsa for control of both the dryers aad the transfer point eaissioas can be prepared aad preseated by Mceaher 31, 1971, sad a schedule for coapliaace can be discussed at that tiae. Depending upon the eaactaeat of Federal legialatioa applying to bar iadastry, however, we aay then aeed to revise the prograa aad schedule. As it has ia the paat, GAP will coatiaee to cooperate with the Teraoat Division of Inrirnnaentil Protection, aad propose to keep yea iafoxaed of progress. Ik I >1 GAF 11177