Post on 15-Jan-2016
The History of Trona Cloud Hazardous Air Pollutants
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Furnace
Calciner
An Industrial furnace and a rotating cylinder, called a “calciner”, are used to convert trona into soda ash.
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Furnace
Calciner
Air
Coal / Nat Gas
Coal, or natural gas are used to generate the heat needed. This results in combustion products of CO, CO2, NOX and water vapor.
CO, CO2, NOX, H20
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Furnace
Calciner
Air
Coal / Nat Gas
Extra air is also fed through the furnace and calciner to help carry the heat from the furnace into the calciner.
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Furnace
Calciner
Na2CO3NaHCO32H2O Na2CO3
Trona in Soda Ash out
HEAT
In order to make soda ash, the trona is heated to about 350 F.
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Furnace
Calciner
Na2CO3NaHCO32H2O
2H2O +CO2
Na2CO3
Trona Soda Ash
HEAT
The trona also releases CO2, and H20 (water), with each molecule of trona that is converted to soda ash.
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Furnace
Calciner
Na2CO3NaHCO32H2O Na2CO3
Trona Soda Ash
HEAT
Trona ore is not pure but may contain up to 50% of oil shale products. Typically ore grades are maintained at above 80% trona to conserve energy.
+Insoluble Material / Oil Shale Insoluble Material / Oil Shale
+
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Furnace
Calciner
Na2CO3NaHCO32H2O Na2CO3
Trona Soda Ash
HEAT
When trona ore is heated, oil shale products are also heated, releasing hazardous air pollutants or “HAPS”.
+Insoluble Material / Oil Shale Insoluble Material / Oil Shale
+
HAPs2H2O +CO2
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Furnace
Calciner
Air
Coal / Nat GasTrona + Oil Shale Soda Ash
The State of Wyoming has monitored these smoke stacks or point sources for combustion products (CO, CO2) and particulates, or dust (Opacity).
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Furnace
Calciner
Air
Coal / Nat GasSoda Ash
The State of Wyoming, did not recognize the potential for HAPS until the 1990s, when suspected liquid oil shale products were found in stack monitoring equipment, during routine stack monitor certifications HAPs
Trona + Oil Shale
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Calciner
Soda Ash
The Discovery of HAPs in the 1990’s Sounded Alarms at the State Capital and Corporate Boardrooms !!!
HAPs
HEAT
Trona + Oil Shale
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Calciner
Soda Ash
Tests Were Conducted to Determine the Quantity and Nature of the HAPS
HAPs
HEAT
Trona + Oil Shale
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HAPs testing resulted information about the Trona Cloud to become available on the Internet, at EPA’s
Website
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Questions to the state of Wyoming about asbestos discharges and HAPs
Information, led to the discovery of alarming errors.
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Dave Freudenthal. Governor
T h e S ta te of W yom ing
Departm ent of Environm ental Quality
AD M IN/OUTREA C
H (307)777-7758 FAX 777-3610
Herschler Building • 122 West 25th Street • Cheyenne, Wyoming 82002
ABAN DO NE D M INES A IR Q UA LITY INDU STRIA L S IT IN G LA ND QUA LIT Y SO LID & H AZ. W A STE
(307)777 -6145 (307)777 -7391 (307)777 -7369 (307)777 -77 56 (307)777 -77 52 FAX 777-6462 FAX 777-5616 FAX 777-6937 FAX 777-5864 FAX 777-5973
August 31, 2004 RE: HAPs
...your question about asbestos, we have not specifically entered any data into the EPA database. EPA used data from the National Toxics Institute database for 1996 and we do not know where NTI got it, however they did not get it from us or from the company. We downloaded that database several years ago and found it to be full of errors for a number of sources, so we basically threw it out. EPA has never fixed these problems which is why state agencies are so resistant to use these publicly accessible databases. …
Trona Cloud Information being provided to the public, via the EPA,
was not reliable.
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Dave Freudenthal. Governor
T h e S ta te of W yom ing
Departm ent of Environm ental Quality
AD M IN/OUTREA C
H (307)777-7758 FAX 777-3610
Herschler Building • 122 West 25th Street • Cheyenne, Wyoming 82002
ABAN DO NE D M INES A IR Q UA LITY INDU STRIA L S IT IN G LA ND QUA LIT Y SO LID & H AZ. W A STE
(307)777 -6145 (307)777 -7391 (307)777 -7369 (307)777 -77 56 (307)777 -77 52 FAX 777-6462 FAX 777-5616 FAX 777-6937 FAX 777-5864 FAX 777-5973
August 31, 2004 RE: HAPs
You are correct that in the early 1990s there were no regulatory requirements associated with HAP emissions from trona calciners…. There still are no regulatory requirements.
…As a part of the investigation into this issue, tests were performed and it was determined that these plumes were composed of a number of compounds .. 5 of which are listed HAPs. The total emission of these HAPS was slightly over 5 TPY. …
Again, thanks for your interest…
…the State of Wyoming claimed 5 HAPS and slightly over 10,000
lbs/year…in sharp contrast to the EPA reports…
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Dave Freudenthal. Governor
T h e S ta te of W yom ing
Departm ent of Environm ental Quality
AD M IN/OUTREA C
H (307)777-7758 FAX 777-3610
Herschler Building • 122 West 25th Street • Cheyenne, Wyoming 82002
ABAN DO NE D M INES A IR Q UA LITY INDU STRIA L S ITIN G LA ND QUA LIT Y SO LID & H AZ. W A STE
(307)777 -6145 (307)777 -7391 (307)777 -7369 (307)777 -77 56 (307)777 -77 52 FAX 777-6462 FAX 777-5616 FAX 777-6937 FAX 777-5864 FAX 777-5973
August 31, 2004 RE: HAPs
…The quantification of HAPs back then was related to the observation of a blue plume sometimes formed some distance from the stack exit. The question at that time was whether compliance with opacity standards should be evaluated at the stack exit or downwind, where we knew a mixture of water vapor and condensable organic matter resulted in the blue plume…
Again, thanks for your interest…
…but the quantification of HAPs was based on just looking at the sky...
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Dave Freudenthal. Governor
T h e S ta te of W yom ing
Departm ent of Environm ental Quality
AD M IN/OUTREA C
H (307)777-7758 FAX 777-3610
Herschler Building • 122 West 25th Street • Cheyenne, Wyoming 82002
ABAN DO NE D M INES A IR Q UA LITY INDU STRIA L S ITIN G LA ND QUA LIT Y SO LID & H AZ. W A STE
(307)777 -6145 (307)777 -7391 (307)777 -7369 (307)777 -77 56 (307)777 -77 52 FAX 777-6462 FAX 777-5616 FAX 777-6937 FAX 777-5864 FAX 777-5973
August 31, 2004 RE: HAPs
…The quantification of HAPs back then was related to the observation of a blue plume sometimes formed some distance from the stack exit. The question at that time was whether compliance with opacity standards should be evaluated at the stack exit or downwind, where we knew a mixture of water vapor and condensable organic matter resulted in the blue plume…
Again, thanks for your interest…
…but the quantification of HAPs was based on just looking at the sky...
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Calciner
Trona Soda Ash
HEAT
Oil Shale Products
HAPs…looks like 5 HAPs and
only 5 Tons per Year…looks like 5 HAPs and
only 5 Tons per Year…looks like 5 HAPs and
only 5 Tons per Year
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What goes into The Trona Cloud ???
Calciner
Trona Soda Ash
HEAT
Oil Shale Products
HAPs
What goes into The Trona Cloud ???
Maybe we better run some tests…
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Calciner
Trona Soda Ash
HEAT
Oil Shale Products
HAPs
What goes into The Trona Cloud ???
…oops…using these emission (FUDGE)
factors, it looks more like 25 HAPs and 2 million
pounds per year…
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1,3-ButadieneAcetaldehydeAcetophenone
AcroleinAcrylonitrile
Antimony CompoundsArsenic Compounds
AsbestosBenzene
Beryllium CompoundsBiphenyl
Bis(2-Ethylhexyl)PhthalateCadmium Compounds
Carbon DisulfideChlorobenzene
Chromium CompoundsCobalt Compounds
CumeneDibenzofuranEthylbenzene
Ethylene DichlorideFormaldehyde
HexaneHydrochloric AcidHydrogen Fluoride
IsophoroneLead Compounds
Manganese CompoundsMercury Compounds
Methyl ChlorideMethyl Chloroform
Methyl Ethyl KetoneMethylene ChlorideNickel CompoundsPerchloroethylene
PhenolPolycyclic Organic Matter
Polycyclic Organic Matter as 16-PAHPropionaldehyde
Selenium CompoundsStyreneToluene
TrichloroethyleneXylenes (Mixed Isomers)
Trona Cloud HAPS Were Identified and Quantified(2 Million Lbs Per Year)
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Trona HAPs Reporting -The Fruits of a Poisonous Tree?
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Trona HAPs Reporting -The Fruits of a Poisonous Tree?
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??? 1990’s Test Work ???
Trona HAPs Reporting -The Fruits of a Poisonous Tree?
??? 1990’s Test Work ???
Assumptions
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Trona HAPs Reporting -The Fruits of a Poisonous Tree?
Assumptions
Emission
Factors
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??? 1990’s Test Work ???
Trona HAPs Reporting -The Fruits of a Poisonous Tree?
Emission
Factors
Emission
Factors
Clean Air Act Compliance
Assumptions
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??? 1990’s Test Work ???
Trona HAPs Reporting -The Fruits of a Poisonous Tree?
Emission
Factors
Emission
Factors
Clean Air Act Compliance
Assumptions
To be continued?
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??? 1990’s Test Work ???